Privacy Policy

1. Data Collected

During your use of the Service, we may collect and process the following information:

• Your Solana wallet public address (public key);
• Wallet private key (in encrypted form — see Section 2);
• Telegram identifier (Telegram ID) and username;
• IP address when accessing the web interface;
• Data about transactions made through the Service (transaction hashes, amounts, pool addresses);
• LP strategy settings (range width, capital allocation);
• Technical browser and device information (User-Agent);
• Interface language and user preferences.

2. Private Key Storage

Private keys are processed with the following security measures:

• Encryption: envelope encryption — each record has its own data key (Fernet, AES-128-CBC), which is wrapped by an AWS KMS master key; the master key never leaves AWS KMS, and only the wrapped data key is sent to AWS — the private key itself never is;
• Records not yet migrated to AWS KMS remain on the legacy scheme: Fernet algorithm (AES-128-CBC), key derived via PBKDF2-HMAC-SHA256 with 600,000 iterations and a unique salt for each key;
• Private keys are NEVER stored in plaintext (unencrypted) form;
• Private keys are NEVER shared with third parties;
• Private keys are NEVER written to log files;
• Decryption is performed only at the moment of transaction signing and only in RAM;
• With 2FA enabled, money operations require a 2FA code; withdrawals can be restricted to an address whitelist and a daily limit;
• When you connect an external wallet (e.g. Phantom), the private key is not sent to the server: you sign transactions yourself;
• Users can delete their private key from the server by disconnecting their wallet.

Despite the security measures taken, no system is absolutely secure. We recommend using a separate wallet for the bot.

3. Data Usage

Collected data is used exclusively for the following purposes:

• Signing and sending transactions on the Solana blockchain on behalf of the user;
• Managing LP positions (opening, closing, fee collection, rebalancing);
• Analyzing market conditions for AI decision-making;
• Generating activity and profitability reports;
• Operating the subscription and authorization system;
• Technical support and processing user requests;
• Improving the quality and security of the Service.

4. Third-Party Data Sharing

We do NOT sell, rent, or share your personal data with third parties, except in the following cases:

• Blockchain interaction: public keys and transaction data are public information on the blockchain;
• Telegram Bot API: your Telegram ID is transmitted to Telegram to operate the bot;
• AWS KMS: to decrypt a key, only the wrapped data key is sent to AWS KMS (see Section 2); the wallet private key is never sent there;
• Legal requirements: we may disclose information if required by law, court order, or government request;
• Rights protection: to protect our rights, property, or the safety of users.

We never share private keys, encrypted data, or confidential information about user strategies with third parties.

5. Blockchain Data

You acknowledge that transactions on the Solana blockchain are:

• Public — viewable by anyone through blockchain explorers (Solscan, Solana Explorer);
• Irreversible — once confirmed, a transaction cannot be reversed;
• Permanent — transaction data is stored on the blockchain indefinitely.

Data recorded on the blockchain cannot be deleted or modified and is not considered personal data subject to protection under this policy. We do not control and are not responsible for the public availability of this data.

6. Cookies and Analytics

The Service web interface uses a minimal set of technical tools:

• localStorage: for saving language preferences (ru/en);
• JWT tokens: for session authentication (stored only in browser memory, not in localStorage);
• We do NOT use third-party tracking cookies;
• We do NOT use Google Analytics, Facebook Pixel, or similar analytics services;
• Server log files may contain IP addresses and User-Agent for diagnostics and security purposes.

7. Data Retention

We retain your data for the following periods:

• Account data and settings: for the duration of account activity;
• Encrypted private keys: until the wallet is disconnected by the user;
• Transaction data: up to 12 months for report generation;
• Server logs: up to 30 days;
• Upon account deletion: all data, except blockchain records, is deleted within 30 days.

8. User Rights

You have the right to:

• Request information about stored personal data;
• Request deletion of your data from our servers (except data recorded on the blockchain);
• Withdraw consent for data processing by ceasing to use the Service;
• Disconnect your wallet, which will result in deletion of the encrypted private key;
• Export transaction history and reports.

To exercise these rights, contact us through the Telegram bot (@AI_LP_Trade_bot) or the support ticket system.

9. Security Measures

We implement the following measures to protect your data:

• Data encryption in transit (HTTPS/TLS);
• Private key encryption at rest (Fernet/AES, data key wrapped by an AWS KMS master key — see Section 2);
• Server infrastructure isolation (Docker containerization);
• Rate limiting to protect against brute force attacks;
• Regular software and dependency updates;
• Monitoring and logging of suspicious activity.

No security system is absolute. We recommend users observe their own security precautions, including using a separate wallet and strong passwords.

10. Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. We will notify you of changes through:

• Telegram bot (@AI_LP_Trade_bot);
• Updating the "Last updated" date on this page.

Continued use of the Service after changes are made constitutes your acceptance of the updated Policy.

11. Contact Information

For any questions regarding personal data processing, privacy, or this policy, you can contact us:

• Telegram bot: @AI_LP_Trade_bot
• Support system: "Support" section in the web interface or Mini App

Effective date: February 27, 2026.