Privacy Policy

Effective date / version: [EFFECTIVE DATE] (draft, version [VERSION])

DRAFT — not legally reviewed — not ready for publication

This document is a working draft prepared from inspected source code, not from verified deployed settings or signed contracts. It has not been reviewed by a qualified lawyer and is not legal advice. Text in [BRACKETS] is a fact the owner must still supply and approve; nothing here establishes who operates the service, which law applies, how long data is kept, or what refund rights apply. Its presence on this page is not permission to launch or take payments.

Draft status: facts the owner must supply and approve before publication
  • [LEGAL ENTITY NAME], [TRADING NAME IF DIFFERENT], [COUNTRY], [REGISTERED BUSINESS ADDRESS], [REGISTRATION NUMBER OR NOT APPLICABLE], [VAT/TAX STATUS].
  • [SUPPORT EMAIL], [PRIVACY CONTACT], [MONITORED TELEGRAM SUPPORT CHANNEL IF USED], [SUPPORT RESPONSE TARGET]. No mailbox monitoring or test message has been verified.
  • [ELIGIBLE COUNTRIES], [MINIMUM AGE IF HIGHER THAN 18], [GOVERNING LAW], [COMPETENT COURTS], [APPLICABLE CONSUMER DISPUTE RESOLUTION ROUTE]. Local mandatory consumer rights cannot be contracted away.
  • [REFUND AND WITHDRAWAL PROCESS], [STATUTORY WITHDRAWAL PERIOD AND EXCEPTIONS IF APPLICABLE], [DIGITAL-SERVICE COMMENCEMENT CONSENT FLOW IF REQUIRED]. The inspected app does not prove a valid waiver/checkbox/consent record or self-service cancellation/deletion workflow. Do not claim one exists.
  • [DATA CONTROLLER CONTACT/REPRESENTATIVE IF REQUIRED], [HOSTING PROVIDER LEGAL ENTITY AND DATA CENTER COUNTRY], [PROCESSOR CONTRACTS AND LOCATIONS], [INTERNATIONAL TRANSFER SAFEGUARDS], [SUPERVISORY AUTHORITY]. Code/docs identify DigitalOcean hosting, Resend email, OpenAI generation, The Odds API sports data, NOWPayments and Telegram; exact contracts, roles, regions and settings need owner confirmation.
  • Retention decisions and operational enforcement: [ACCOUNT RETENTION], [OTP RECORD RETENTION], [PAYMENT AND TAX RECORD RETENTION], [SUPPORT RETENTION], [SERVER AND SECURITY LOG RETENTION], [BACKUP RETENTION AND DELETION CYCLE]. Expiry of an OTP is NOT deletion of the OTP record.
  • [RIGHTS REQUEST HANDLER AND VERIFICATION PROCESS], [SECURITY/INCIDENT CONTACT AND PROCESS], [EFFECTIVE DATE], [VERSION]. No guaranteed deletion deadline or backup purge should be invented.
  • Confirm displayed plan benefits, sports scope and any consumer remedy for unavailable paid features. Web membership and Telegram VIP are separate; web digest and cross-account linking are not accepted capabilities. No new auto-renewal, analytics or tracking feature is authorized.

1. Who is responsible

[LEGAL ENTITY NAME], [REGISTERED BUSINESS ADDRESS], [COUNTRY], is the controller of personal data processed to operate Don Quack, subject to confirmation of applicable legal roles. Privacy contact: [PRIVACY CONTACT]. Representative/DPO if required: [DATA CONTROLLER CONTACT/REPRESENTATIVE IF REQUIRED].

2. Information processed

  • Web account and sign-in: email address, internal account identifier, verification status, login timestamps, one-time-code hash, code expiry/attempt/consumption records and request IP address for abuse prevention. Code expiry is not a promise that the database row is deleted. Some authentication/rate-limit logs can contain email and IP address.
  • Telegram: Telegram numeric user/chat identifier, username where provided, interface language and interaction/account records needed for bot replies, preferences, cooldowns, subscriptions and VIP fulfilment. Telegram separately processes information under its own policy. We do not claim to collect your entire Telegram chat history or phone number from ordinary bot use.
  • Service usage: chosen sports/leagues/language, forecast content and event identifiers, history timestamps, results and subscription/access state. We store information needed to enforce plan limits and show available history.
  • Payments: account/order/invoice/payment identifiers, plan, quoted USD/Stars amount, currency and status, timestamps, provider charge identifiers and signed callback-event records, including the provider callback payload. Depending on the provider payload this may contain blockchain transaction/payment-address details. We do not ask for a wallet seed phrase or private key and do not operate a bank-card vault. NOWPayments and Telegram may collect additional payment information independently. Public blockchain transactions may remain publicly visible beyond our control.
  • Operations/support: technical request/security/error logs (which can include IP, request metadata and relevant account/payment references), correspondence and attachments you choose to send support, and backup copies. Do not send wallet secrets or sensitive documents unnecessarily.

3. Why we use it and legal bases where applicable

We use account, forecast, preference and subscription data to deliver the requested service and fulfil purchases (contract/performance at your request); sign-in/security records to prevent abuse and secure systems (legitimate interests, balanced against your rights); and payment/accounting records for legal obligations where applicable. Support processing may be necessary for contract performance, legitimate interests or legal compliance according to the request. Any optional marketing or non-essential tracking would need a separate lawful basis and, where required, consent; this draft does not authorize either. We do not describe sports forecasts as automated decisions producing legal or similarly significant effects about you.

4. Recipients and third-party services

Access is limited to authorized operators and service providers as needed, subject to [PROCESSOR CONTRACTS AND LOCATIONS]. Source identifies:

  • Hosting/infrastructure: DigitalOcean in project documentation; actual contracting entity/region: [HOSTING PROVIDER LEGAL ENTITY AND DATA CENTER COUNTRY].
  • Resend for sign-in and transactional emails (recipient email and relevant email content).
  • NOWPayments for hosted crypto checkout and payment notification processing (order/plan/price, provider transaction details and status); Telegram for bot interactions, Stars payments and VIP channel functions. Their roles may be independent-controller and/or processor depending on the function and contract.
  • The Odds API for sports fixtures/odds/results queries. Inspected requests use sport/event identifiers and API authentication, not an intentional email/Telegram-profile payload.
  • OpenAI for AI-generated sports commentary. Inspected generation constructs prompts from match information, estimated pick data and requested language, not intentionally from account email or Telegram ID. Provider retention/training/region settings are not verified; do not claim zero retention or no training without contractual evidence.

We may disclose data to competent authorities when legally required or to protect legitimate rights subject to applicable safeguards. No advertising sale or new ad-pixel integration is part of this draft. Third-party sites/checkout have their own policies; review them before use.

5. Browser storage and tracking

The inspected web app uses localStorage dq_token for the sign-in session token and dq_lang for your language preference. The source default session lifetime is 30 days, configurable; token expiry does not necessarily physically remove the stored item. Signing out removes the token from that browser; language preference persists until changed or cleared. Clearing site storage removes local copies and may sign you out but does not delete server records. These are not described as one single storage item or as sessionStorage-only. The inspected product has no authorized analytics/advertising pixels in this scope; do not add them without a separate review and required notice/consent. Hosting and request logs are distinct from ad tracking.

6. Retention

We minimize retention according to service, security and legal needs. Inspected cleanup normally deletes forecasts older than 30 days; this is not a promise that every type of personal data is deleted after 30 days. Unrelated Top Picks and sent markers normally have a seven-day cleanup rule, but picks referenced by pending accumulators are preserved and can persist longer. Retention can therefore affect displayed performance history.

Accounts/preferences: [ACCOUNT RETENTION]. OTP/database request records: [OTP RECORD RETENTION] (default sign-in code validity is 10 minutes, not a deletion policy). Payment, subscription and accounting records: [PAYMENT AND TAX RECORD RETENTION]. Logs: [SERVER AND SECURITY LOG RETENTION]. Support: [SUPPORT RETENTION]. Backups: [BACKUP RETENTION AND DELETION CYCLE]. Legal holds may require longer retention, restricted to that purpose. Owner must establish and test these schedules; no automatic full-account deletion or immediate purge from backups is claimed.

7. Your requests and rights

Contact [PRIVACY CONTACT] to request access, correction, deletion, restriction, objection or portability where applicable, or to withdraw consent for any consent-based processing without affecting prior lawful use. We may need proportionate identity verification and may retain records required by law or for legitimate claims. Rights workflow: [RIGHTS REQUEST HANDLER AND VERIFICATION PROCESS]. The app does not currently provide a verified self-service full-account deletion button; clearing localStorage or signing out is not account deletion. You may complain to [SUPERVISORY AUTHORITY] or the relevant authority where you live/work when applicable. Statutory response deadlines apply; this draft does not invent a different period.

8. Security and international transfers

Source includes hashed one-time codes, expiring signed sessions, authenticated ownership-scoped account/payment access and signed payment-callback checking. No system is risk-free; these design measures are not an independent security certification or assurance that all deployment settings are correct. Security/incident contact/process: [SECURITY/INCIDENT CONTACT AND PROCESS]. Processing may occur outside your country through the providers above. Destinations and appropriate safeguards: [INTERNATIONAL TRANSFER SAFEGUARDS]. Do not assert EU-only storage or adequacy/standard clauses until confirmed.

9. Children and updates

The service is intended for adults aged at least 18 or the higher applicable minimum; we do not knowingly offer it to children. Contact [PRIVACY CONTACT] if you believe a child has supplied data so that the responsible operator can assess and take appropriate action. Material changes to processing will be reflected here and notified where required. This draft is not consent to undisclosed future processing.

Contact for this document: [SUPPORT EMAIL] / [PRIVACY CONTACT] (not yet confirmed by the owner).