Privacy Policy

This Privacy Policy explains how the operator of the Mite application and related interfaces (the “Operator”, “we”, “us”, or “our”) collects, uses, and protects information in connection with the Mite application, Telegram Mini App, website, and related services (collectively, the “Service”). By using the Service, you agree to the practices described in this Policy. If you do not agree, do not use the Service.

1. Who We Are

For the purposes of applicable data-protection laws, the data controller is the Operator of the Service. Contact details are provided in Section 13.

2. Our Approach to Data

We are committed to data minimization. The Service is designed to operate with as little personal data as reasonably possible. Much of the activity on the Service occurs on public blockchain networks and through third-party platforms that we do not control.

3. Information We Collect

Information you provide. This may include an invitation code, a Telegram identifier or username (where you access the Service via Telegram), and any information you voluntarily submit when contacting us.

Wallet and on-chain information. When you interact with the Service, we may process public blockchain addresses and associated public transaction data. Blockchain data is inherently public and is not controlled by us.

Technical and usage information. We may automatically collect limited technical information such as device type, browser type, approximate location derived from IP address (for the purpose of enforcing geographic restrictions), access timestamps, and interaction logs.

Cookies. The website uses only strictly necessary cookies required for the website to function. We do not use advertising cookies.

We do not knowingly collect special categories of personal data, and we do not request your private keys, seed phrases, or passwords — and you should never share them with us or anyone else.

4. How We Use Information

To provide, operate, and maintain the Service, including verifying invitations and enabling access during the closed beta.

To enforce eligibility and geographic restrictions and to comply with applicable laws, including sanctions screening and anti-money-laundering obligations.

To improve, secure, and troubleshoot the Service.

To communicate with you, including responding to enquiries and sending service-related notices.

To detect, prevent, and address fraud, abuse, security incidents, and violations of our terms.

5. Legal Bases for Processing

Where the GDPR or similar laws apply, we rely on the following legal bases: (a) performance of a contract with you; (b) compliance with a legal obligation, including sanctions and AML requirements; (c) our legitimate interests in securing, improving, and protecting the Service, balanced against your rights; and (d) your consent, where required.

6. Third-Party Platforms and Processors

The Service enables interoperability with independent third-party platforms (including prediction markets) and relies on infrastructure providers. When you interact with a third-party platform, that platform processes your information under its own privacy policy, which we do not control.

We may use third-party service providers to operate the Service — for example, hosting, analytics, identity-verification, sanctions-screening, and confidential-compute providers. These providers process information on our behalf and are bound by appropriate contractual obligations.

Where AI inference is performed via a confidential-compute network, requests may be processed inside hardware-attested secure enclaves designed so that the underlying compute providers cannot access the contents of those requests.

7. Sharing of Information

We do not sell your personal data. We may share information: (a) with service providers and processors as described above; (b) where required by law, regulation, legal process, or governmental request; (c) to enforce our terms or protect the rights, safety, and property of the Operator or others; and (d) in connection with a corporate transaction such as a merger, acquisition, or reorganization.

8. International Transfers

Information may be processed in jurisdictions other than your own, which may have different data-protection standards. Where required, we implement appropriate safeguards for international transfers, such as standard contractual clauses or equivalent mechanisms.

9. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy, or as required to comply with legal, regulatory, accounting, or reporting obligations. Public blockchain data cannot be altered or deleted by us.

10. Your Rights

Depending on your jurisdiction, you may have rights to access, rectify, erase, restrict, or object to the processing of your personal data; data portability; and withdrawal of consent. You may also have the right to lodge a complaint with a supervisory authority. To exercise your rights, contact us using the details in Section 13. We may need to verify your identity before responding. Please note that we may be unable to act on blockchain data that is outside our control.

11. Security

We implement reasonable technical and organizational measures designed to protect information against unauthorized access, loss, or misuse. However, no system is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your wallets, keys, and credentials.

12. Children

The Service is not directed to, and may not be used by, anyone under 18 years of age (or the age of majority in your jurisdiction, if higher). We do not knowingly collect personal data from minors. If you believe a minor has provided us information, contact us and we will take appropriate steps.

13. Changes and Contact

We may update this Policy from time to time. Material changes will be indicated by updating the “Last updated” date. Your continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

For questions or to exercise your rights, contact us at: hello@mite.market.