Draft v0.1 · 06/10/2026 · subject to legal review
1. Controller
[Company name] Ltd, [address], United Kingdom, is the data controller. Contact: [privacy email].
2. Our principle
NoPeek is a privacy tool, so we collect as little as we can. No advertising trackers, no third-party cookies, no selling of data, no profiling of you as a person.
3. What we process, why, and for how long
| Data | Why | Basis | Kept |
|---|---|---|---|
| Email (waitlist fallback) | tell you when access opens | consent | until you unsubscribe, max 12 months after launch |
| Telegram user ID, username, language | run the bot, rate-limit, deliver reports, payments and refunds, waitlist activity | contract | while you use the bot + 12 months |
| Payment records (Stars IDs, USDC tx hashes, amounts) | deliver paid features, refunds, accounting | contract; legal obligation | 7 years |
| Wallet and contract addresses you submit | run the check | contract | 30 days in logs; results may be cached without link to you |
| Public blockchain data | the Service itself | legitimate interest | indefinitely; it is public |
| Technical logs (hashed IP, time, errors) | security, abuse prevention | legitimate interest | 30 days |
| Cloudflare Turnstile and cookieless analytics | keep the site working, count visits | legitimate interest | per Cloudflare |
We do not combine your wallet addresses with your email or Telegram identity unless you explicitly link them in a paid feature, and we tell you when that happens.
4. Processors and third parties, including ChangeNOW
Cloudflare (hosting, security, analytics), Telegram (bot platform, Stars payments), Supabase (waitlist and bot database, EU region), block explorers and data providers (public chain data).
If you choose the Fresh-wallet feature in the bot, the swap is performed by ChangeNOW (CHN Group LLC) and ChangeNOW becomes an independent controller of the data you give them: the addresses you send from and to, the amounts, your IP address, and, if their AML/KYC rules require it, identity documents verified through their provider (Sumsub). Their Privacy Policy (https://changenow.io/privacy-policy) and AML/KYC Policy (https://changenow.io/terms-of-use/aml-kyc) apply. NoPeek receives from ChangeNOW only a transaction reference and the affiliate fee amount for accounting, never your identity documents, and we do not share your Telegram identity or email with ChangeNOW. We do not sell or rent data to anyone.
5. International transfers
Data is stored in the EU/UK where possible. Cloudflare, Telegram and ChangeNOW may process data elsewhere under standard contractual clauses or equivalent safeguards.
6. Your rights
You can ask for access, correction, deletion, restriction, portability, or object to processing, and withdraw consent at any time: [privacy email] or /privacy in the bot. You can complain to the UK Information Commissioner's Office (ico.org.uk) or your local EU data authority. For data held by ChangeNOW, contact ChangeNOW directly.
7. Cookies
The website sets no cookies of its own. Cloudflare may set a strictly necessary security cookie. We use cookieless analytics. No consent banner is shown because nothing non-essential is set.
8. Children
The Service is not for anyone under 18. We do not knowingly collect data from children.
9. Changes
We post changes here with a new date. Material changes are announced in the Telegram group.

