This Privacy Policy describes how Underpaws Telegram mini-app (the "Mini-App," "Company," "we," "us," or "our"), collects, uses, stores, and shares information about you ("User," "you," or "your") when you access or use the Underpaws Telegram mini-app and all associated services (collectively, the "Services"). The Mini-App is available within the Telegram Messenger application and is designed to provide a similar user experience as the Underpaws Telegram bot.

This Privacy Policy is incorporated into and forms part of our Terms and Conditions. By accessing or using the Services, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services.

This Privacy Policy is a supplement to the Telegram Privacy Policy and the Third-Party Services Privacy Policy as described in Section 6 of the Telegram Privacy Policy for Third-Party Services. By using this Mini-App you are also agreeing to be bound by https://telegram.org/privacy/ and Third-Party Services Privacy Policy: https://telegram.org/privacy-tpa.

1. Information We Collect
We collect the following types of information that may be considered personal data:
1.1. Information You Provide Directly:
1.1.1. Telegram Data: When you authorize the Mini-App through Telegram, we receive your:

• Telegram User ID.
• Public Telegram Name.
• Username.
• Profile picture.
• Telegram Premium user status.

This data is used for in-game leaderboards, the correct operation of the referral system, and maintaining your in-game progress.
1.2. Information Collected Automatically:
1.2.1. Telegram app platform.
1.2.2. Telegram app version.
1.2.3. Initial IP Address: We receive your IP address when you first log in for geolocation purposes. This data is not stored after the initial determination of your location.
1.2.4. Device ID: A unique identifier assigned to your device on first use, used to save progress before authorization. This identifier is not linked to any personal information before authorization.
1.2.5. Device Information: We collect data about your device, including the device model, operating system, and a unique device identifier. This information is linked to your account in our database and stored as an alphanumeric code. We collect and store this data for use in analytics services and to monitor the security of your session. For instance, if we detect a login under the same session from a different IP address or device (which may indicate session key theft), we will reset the session.
1.3. Information from Third Parties:
1.3.1. Analytics Data: We use third-party analytics services, such as Google Analytics, to collect and analyze usage data. These services may collect your IP address.
1.4. Generated Data:
1.4.1. In-game activity data: We generate and analyze data related to your in-game activity, achievements, and progress within the Mini-App. This data is used to operate and improve the Services, personalize your experience, and for our anti-cheat system.

2. How We Use Your Information
2.1. We use the information we collect for the following purposes:
2.1.1. To Provide and Maintain the Services: ·To operate the Mini-App and its features.

• To authenticate your access to the Services.
• To process your requests and transactions.
• To track your in-game progress and achievements.

2.1.2. To Personalize Your Experience:

• To customize the content and features you see within the Mini-App.
• To provide you with relevant recommendations and offers.
• To create and maintain in-game leaderboards.

2.1.3.To Communicate with You:

• To send you important updates and announcements about the Services.
• To respond to your inquiries and provide customer support.

2.1.4. To improve the Services:

• To analyze usage patterns and identify areas for improvement.
• To develop new features and functionalities.
• To conduct research and testing.

2.1.5. To Prevent Fraud and Abuse:

• To detect and prevent fraudulent activity, cheating, and other misuse of the Services.
• To monitor session security and prevent unauthorized access to your account.
• To enforce our Terms and Conditions.

2.1.6. To Comply with Legal Obligations:

• ·To comply with applicable laws, regulations, and legal processes.

2.1.7. To Operate the Referral System:

• To track referrals and distribute rewards accordingly.

2.1.8. To Display Leaderboards:

• To publicly display user rankings and achievements within the Services, using publicly available information such as your Telegram name, username, and profile picture, along with your in-game progress data.

2.1.9. To operate Anti-Cheat system:·To analyze your in-game activity to detect and prevent cheating, including the use of multiple accounts (multi-accounting), autoclickers, bots, and other methods of gaining an unfair advantage. Please note that our anti-cheat system is automated, and if it flags your account for suspicious activity, your in-game progress and achievements may be affected without prior notice.

3. How We Share Your Information
3.1. We may share your information in the following circumstances:
3.1.1. With Telegram: As a Telegram mini-app, certain data is shared with Telegram as outlined in Telegram's Privacy Policy. This may include your, Telegram User ID, your public account data: your screen name, username and profile picture(s), premium status, and theme color parameters.
3.1.2. With Third-Party Service Providers: We may share your information with third-party service providers who perform services on our behalf, such as analytics, cloud storage, and security monitoring. These service providers are contractually obligated to protect your data and use it only for the purposes for which it was shared.
3.1.3. For Legal Reasons: We may disclose your information if required to do so by law or in response to a valid legal request, such as a subpoena or court order.
3.1.4. To Protect Our Rights: We may disclose your information to protect our rights, property, or safety, or the rights, property, or safety of others.

4. Third-Party Services
4.1. We use the following third-party services:
4.1.1. Yandex Metrica: We use the Yandex Metrica web analytics service provided by Yandex LLC (hereinafter referred to as "Yandex"). Yandex Metrica uses "cookies," small text files placed on users' computers to analyze user activity. Information collected by cookies does not reveal your identity, but it can help us to improve our website performance. Information about your use of this website collected by cookies will be transferred to Yandex and can be stored on Yandex's servers in the EEA and/or Russia. Yandex will process this information on behalf of the website owner, inter alia, to assess how you use the website, compile reports on your usage of website. Yandex processes this information as specified in the Terms of Use of Yandex Metrica Service. You can opt out of using cookie files by choosing the corresponding settings in your browser. You can also use the tool https://yandex.com/support/metrika/general/opt-out.html. However, it can affect some website functions. By using this website, you agree that your data can be processed in the above manner and for the above purposes.
4.1.2. Other Third-Party Links and Advertisements: Our Mini-App may display advertisements or contain links that lead to third-party websites and applications, including but not limited to links to games, apps, services in the Mini-App, and referral links of advertising integrations. These external platforms are not controlled or endorsed by us. We do not have control over their content, accuracy, or practices. When you click on an advertisement or a link and leave this Mini-App, you do so at your own risk. We strongly encourage you to review the Terms & Conditions and Privacy Policy of any third-party website or application before interacting with it. We are not responsible for any loss, damage, or other issues that may arise from your use of these external platforms. Your interactions with any third-party content, including downloading or installing other applications, are solely your responsibility.

5. Data Security
5.1. We take reasonable measures to protect your information from unauthorized access, use, or disclosure. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your information.

6. Data Retention
6.1. We retain your information for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. When you delete your account, we will delete your data.

7. Your Rights
7.1. You have the following rights regarding your information:
7.1.1. Access: You can request access to the personal information we hold about you.
7.1.2. Rectification: You can request that we correct any inaccurate or incomplete information we hold about you.
7.1.3. Erasure: You can request that we delete your personal information. You can delete your account and all associated data within the Mini-App settings.
7.1.4. Restriction of Processing: You can request that we restrict the processing of your personal information in certain circumstances.
7.1.5. Withdraw Consent: If we are processing your personal information based on your consent, you can withdraw your consent at any time.
7.2. To exercise these rights, please contact us using the contact information provided below.

8. Governing Law and Dispute Resolution
8.1. These Terms shall be governed by and construed in accordance with the laws of Hong Kong, without regard to its conflict of laws principles.
8.2. Any dispute, controversy, or claim arising out of or relating to these Terms, or the breach, termination, or invalidity thereof, shall be settled exclusively by the competent courts of Saint Vincent and the Grenadines. You hereby irrevocably consent to the exclusive jurisdiction and venue of such courts.

9. Changes to this Privacy Policy
9.1. We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy within the Mini-App or through other reasonable means. Your continued use of the Services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

10. Contact Us
10.1. If you have any questions about this Privacy Policy, please contact us at privacy@underpaws.games

Last amended on: June 22^nd 2026