Privacy Policy
DP Smart adheres to the principle of minimal data processing. The Bot collects and processes only the data that is technically necessary for the algorithm and smart contract to function. The Community does not request, store, or process personal data beyond what is described in this Policy.
1. Basic Definitions
| Term | Definition |
| Member | An individual registered in the Bot and who has accepted the Terms of Use |
| Data | Any information relating to a member that is processed by the Bot or recorded on the blockchain |
| Processing | Any action with data: collection, recording, storage, use, transfer, deletion |
| Blockchain data | Information about transactions recorded in the public registry of the TON blockchain and accessible to anyone |
| Smart contract | A program on the TON blockchain that automatically executes the rules for distributing gifts |
| AML check | Automatic verification of fund cleanliness (Anti-Money Laundering) when entering the gift tracking Board |
2. What Data Is Processed
DP Smart processes a minimal set of data necessary for the Bot and smart contract to function. All data categories are listed below.
2.1. Telegram Account Data
| Data | Processing Purpose |
| Telegram ID | Member identification in the Bot system, linking to the Community account |
| Username | Displaying the member on gift tracking Boards for interaction with other members |
| Interface language | Displaying the Bot in the language selected by the member |
2.2. Cryptocurrency Wallet Data
| Data | Processing Purpose |
| Tonkeeper wallet address | Linking to the smart contract for automatic receiving and sending of gifts |
— secret phrase (seed phrase) of the wallet;
— passwords from Telegram account or wallet;
— confirmation codes (SMS, 2FA);
— identity documents (passport, driver's license, etc.);
— phone number, email address;
— bank details or payment card data;
— location data.
If anyone requests the above information from you on behalf of DP Smart — this is fraud. The Community's technical support never requests such information.
2.3. Bot Activity Data
| Data | Processing Purpose |
| Registration date and time | Determining participation period, Priority Algorithm operation |
| Activity status | Maintaining algorithm operation: Global activity (48 days) and Current activity (48 hours) |
| Positions on Boards | Tracking the member's current position on gift tracking Boards (Giver, Builder, Creator, Recipient) |
| Gift history | Recording sent and received gifts, qualification and distribution operation |
| Mentor-partner relationship | Compression algorithm operation, Board placement and qualification |
| Violation counter | Determining temporary blocking periods when leaving the Board or not confirming activity |
| Confirmations when entering the Board | Recording the member's conscious consent to the terms of sending a gift |
3. Blockchain Data
The TON blockchain is a public and immutable registry. All transactions made through the smart contract are recorded on the blockchain and accessible to anyone. This is a fundamental property of the technology, not a decision of the Community.
3.1. With each sending and receiving of a gift, the following is recorded on the TON blockchain:
| • | sender's wallet address; |
| • | recipient's wallet address; |
| • | transaction amount; |
| • | transaction date and time; |
| • | transaction hash (unique identifier). |
3.2. Blockchain data is publicly accessible by nature. It cannot be changed, deleted, or hidden — neither by the Community, nor by the technical team, nor by anyone else. By registering in the Bot, the member accepts and understands this fact.
3.3. Blockchain data does not contain names, phone numbers, addresses, or documents. It contains only wallet addresses — pseudonymous identifiers that by themselves do not allow identification of the owner.
4. AML Check
4.1. With each entry to the gift tracking Board, the smart contract conducts an automatic fund cleanliness check (AML — Anti-Money Laundering).
4.2. What is checked:
| • | source of USDT received to the member's wallet; |
| • | absence of connection with addresses included in sanction lists or suspicious activity databases; |
| • | compliance with international anti-money laundering standards. |
4.3. What is not checked:
| ✓ | Member identity — AML check does not require and does not involve transmission of documents or personal data. |
| ✓ | Wallet balance — only the sufficiency of funds for a specific gift is checked, without analyzing the total balance. |
| ✓ | Activity history outside the Community — the Bot does not analyze other operations in the wallet not related to DP Smart. |
4.4. AML check is conducted automatically. Result: admission to the Board or notification with explanation of the reason for refusal. Check data is not stored and not transferred to third parties.
5. Data Processing Purposes
All data described in section 2 is processed exclusively for the following purposes:
| 1 | Algorithm operation. Ensuring correct functioning of gift tracking Boards: placement, advancement, splitting, compression, qualification, Priority Algorithm. |
| 2 | Transaction execution. Sending and receiving gifts through the smart contract, fund reservation, auto-entry to Boards. |
| 3 | Security. Fund cleanliness check (AML), fraud protection, application of temporary and permanent blocks for violations. |
| 4 | Notifications. Sending system messages in Telegram: information about gifts, timers, activity status, blocks. |
| 5 | Technical support. Processing member requests, account recovery, wallet re-linking. |
| 6 | Transparency. Automatic publication of gift information in a special Telegram reports channel in real time. |
Data is not used for marketing, advertising, profiling, sale to third parties, or any other purposes not specified above.
6. Data Visibility to Other Members
When participating in the Community, part of the data becomes visible to other members. This is necessary for the functioning of gift tracking Boards and transparency of interaction.
| What is visible | Who can see it | Why |
| Username | Members on the same Board | Identification on the Board, ability to contact |
| Position on the Board | Members on the same Board | Transparency of movement on the Board |
| Activity status | Bot algorithm | Compression operation, Recipient determination |
| Fact of sending/receiving gift | Telegram reports channel (public) | Community transparency in real time |
| Transaction (wallet addresses, amount) | TON blockchain (public) | Property of blockchain technology |
If you want to increase your privacy level — use a separate Tonkeeper wallet specifically for participation in the Community. This reduces the possibility of linking your activity in DP Smart with other operations on the blockchain.
7. Data Storage
7.1. Telegram account data and Bot activity data are stored on secure servers throughout the entire period of participation in the Community.
7.2. Blockchain data (transactions) are stored on the TON blockchain indefinitely. This is an inherent property of the technology — blockchain records cannot be deleted by any party.
7.3. Data about confirmations when entering the Board (answers to 8 questions) are stored in the Bot system as proof of the member's conscious consent.
7.4. Technical support request data is stored for the duration of the request review and a reasonable period after its closure.
7.5. In case of permanent account blocking, the wallet address is saved in the smart contract blacklist indefinitely to protect the Community.
8. Data Transfer to Third Parties
DP Smart does not sell, transfer, or provide member data to third parties for commercial, marketing, or advertising purposes.
Data may be accessible to third parties only in the following cases:
| Case | Explanation |
| TON blockchain | Transactions are recorded in a public registry. This is a property of the technology, not an action of the Community. Data contains only wallet addresses and amounts — without names or documents. |
| Telegram | The Bot operates on Telegram infrastructure. Interaction with the Bot is governed by Telegram's Privacy Policy. DP Smart does not control and is not responsible for data processing by Telegram. |
| AML check | When checking fund cleanliness, the wallet address may be verified against public databases of suspicious activity. Personal data is not transferred in this process. |
| Legal requirement | Data may be provided upon a justified request from authorized authorities if required by applicable law. |
9. Data Protection
DP Smart takes organizational and technical measures to protect member data:
| • | Server security. Data is stored on secure servers with restricted access. |
| • | Smart contract. Member funds are protected by the smart contract algorithm. Manual access to funds is excluded. |
| • | Minimization. Only the data set necessary for the Bot and algorithm operation is processed. |
| • | Access control. Only the technical team has access to data within the scope necessary for Bot support and maintenance. |
| • | Monitoring. Monitoring systems operate 24/7 to ensure stability and security. |
10. Member Rights
Each Community member has the following rights regarding their data:
| Right | Description |
| Right to information | The member may request from technical support a list of data that is processed in connection with their account. |
| Right to correction | The member may contact technical support to correct incorrect data (for example, when changing username). |
| Right to terminate participation | The member may stop using the Bot at any time. When participation is terminated, data processing by the Bot ceases. |
| Right to account transfer | The member may transfer their account to a new Telegram ID or new wallet through the recovery service (150 USDT). |
11. Member Responsibility
11.1. The member is independently responsible for the security of their Telegram account. It is recommended to: enable two-factor authentication, set a cloud password, link an active phone number and backup email address.
11.2. The member is independently responsible for the security of their cryptocurrency wallet. It is recommended to: write down the secret phrase on paper and store it in a safe place, not store the secret phrase digitally (notes, cloud), not enter the secret phrase on third-party websites.
11.3. DP Smart is not responsible for loss of access to Telegram account or wallet due to the member's fault. Access recovery is a paid service (150 USDT).
11.4. The member is responsible for the accuracy of data provided during registration and use of the Bot.
12. Notifications
12.1. The Bot sends system notifications to members in Telegram. Notifications inform about: received and sent gifts, activity status, timers (15 minutes, 12 hours), blocks, changes in Board positions, updates to Terms and Rules.
12.2. In "Sleeping" status, the Bot suspends sending notifications. After activity is restored, notifications are enabled automatically.
12.3. The Bot does not send advertising, marketing, or commercial messages. All notifications are exclusively system and informational in nature.
13. Children and Minors
13.1. The DP Smart Community is intended exclusively for adults (18 years and older).
13.2. The Bot is not intended for use by minors. If the technical team becomes aware of a minor's registration, their account will be blocked.
13.3. DP Smart does not knowingly collect data from minors.
14. Policy Changes
14.1. This Policy may be updated. When significant changes are made, members will be notified through the Bot.
14.2. The current version of the Policy is always available in the Community knowledge base at kb.dpsmart.gifts.
14.3. Continued use of the Bot after publication of the updated Policy is considered consent to its new version.
15. Feedback
If you have questions related to data processing or this Policy, you may contact technical support through the Bot @DPSmartBot.
DP Smart Privacy Policy
DP Smart Community — international Community of mutual gifts on the TON blockchain
The current version of the document is always available in the knowledge base: kb.dpsmart.gifts