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Privacy Policy

Last Updated: April 1, 2026

1. Introduction

Welcome to Chelotie ("we," "our," or "us"). Chelotie is a payments platform powered by stablecoin infrastructure that enables individuals and businesses to send and receive payments through instant transfers, payment links, products, and subscriptions.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform. Please read this policy carefully to understand our practices regarding your personal data.

Important: Chelotie operates a delegated custody model. Your wallet is provisioned and managed by a third-party wallet infrastructure provider on your behalf. Your funds are held in your individually assigned wallet and are not commingled with other users' or Platform funds. However, wallet keys are managed by our Wallet Provider, and transactions are signed on your behalf after you provide authorization. See Section 4 for details.

2. Information We Collect

2.1 Information You Provide Directly

When you use Chelotie, you may provide us with the following information:

Account Information:

  • Email address
  • Username
  • Password (hashed and encrypted — we never store plaintext passwords)
  • First name and last name
  • Country
  • Bio/profile description
  • Display photo
  • Social media links (Twitter, Facebook, YouTube) — optional

Payment and Product Information:

  • Product details you create (name, description, pricing, currency, billing type)
  • Payment link configurations and metadata
  • Subscription details (billing frequency, amount, stablecoin type)
  • Transfer details (recipient username or wallet address, amount)

Communication Data:

  • Information you provide when contacting our support team
  • Feedback and survey responses

2.2 Information Collected Automatically

When you use our Platform, we automatically collect:

Technical Information:

  • IP address
  • Browser type and version
  • Device information
  • Operating system
  • Pages visited and time spent
  • Referral URLs
  • Clickstream data

Usage Information:

  • Transaction history and payment details
  • Feature usage patterns
  • Log data and error reports

Wallet and Blockchain Information:

  • Your wallet addresses (embedded wallet address and smart wallet address), as provisioned by our Wallet Provider
  • Wallet identifiers associated with your account
  • Transaction hashes and on-chain data (publicly available on blockchain)
  • Network and token information

2.3 Information from Third-Party Services

  • Wallet provisioning data from our Wallet Provider (wallet addresses, wallet identifiers, provider metadata)
  • Transaction bundler confirmations and receipts
  • Social media data if you link your social media accounts (optional)

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Provide Our Services

  • Create and manage your account, including provisioning a wallet through our Wallet Provider
  • Process instant transfers, payment link payments, and subscription billing
  • Send verification codes for transaction authorization
  • Send transaction notifications and payment confirmations
  • Manage product listings and payment links
  • Provide customer support

3.2 Improve Our Platform

  • Analyze usage patterns to improve user experience
  • Develop new features and services
  • Monitor and maintain platform security and performance
  • Debug and resolve technical issues

3.3 Communication

  • Send service-related emails (payment confirmations, subscription updates, verification codes)
  • Respond to your inquiries and support requests
  • Send platform updates and important notices (including changes to terms or fees)
  • Provide marketing communications (with your consent, where required by law)

3.4 Legal and Security

  • Comply with legal obligations and regulatory requirements
  • Prevent fraud, unauthorized transactions, and platform abuse
  • Enforce our Terms of Service
  • Protect our rights and the rights of our users

4. Wallet Infrastructure and Data

Delegated Custody Model: Chelotie uses a third-party Wallet Provider to create and manage smart wallets on behalf of users. Understanding how your wallet data is handled is critical to informed use of the Platform.

4.1 What We Store

When your wallet is provisioned, we store the following data in our systems:

  • Your embedded wallet address
  • Your embedded wallet identifier
  • Your smart wallet address
  • Your user identifier
  • Wallet provider metadata

4.2 What the Wallet Provider Stores

Our third-party Wallet Provider manages:

  • The cryptographic keys associated with your wallet
  • Wallet infrastructure and signing capabilities
  • Key management and recovery systems

Chelotie does not directly access or store your private keys. However, the Platform may instruct the Wallet Provider to sign transactions on your behalf after you provide authorization (e.g., by entering a verification code).

4.3 What We Do Not Store

  • Your private keys or seed phrases
  • Raw cryptographic signing material
  • Your funds — digital assets remain in your individually assigned wallet on the blockchain

4.4 Wallet Provider Disclosure

By creating a Chelotie account, you acknowledge that a wallet will be automatically provisioned for you through our Wallet Provider. The Wallet Provider's handling of your data is governed by its own privacy policy and terms. We recommend reviewing the Wallet Provider's policies, which are available upon request at [Your Support Email].

5. Blockchain Transparency

Chelotie processes payments on public blockchain networks. You should be aware that:

  • Stablecoin transactions are recorded on public blockchains and are permanently visible
  • Transaction details — including wallet addresses, amounts, and timestamps — are publicly accessible
  • This on-chain data cannot be deleted, modified, or made private by Chelotie or any party
  • Anyone with a wallet address can view its full transaction history on a blockchain explorer
  • We cannot control or limit access to blockchain data

6. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following limited circumstances:

6.1 Wallet Infrastructure Provider

  • We share necessary account and transaction data with our Wallet Provider to provision wallets, sign transactions, and process payments
  • The Wallet Provider processes this data in accordance with its own privacy policy

6.2 Service Providers

  • Cloud hosting and infrastructure providers
  • Email delivery services (for verification codes, notifications, and communications)
  • Transaction bundler services (for submitting transactions to the blockchain)
  • Analytics providers
  • All service providers are contractually obligated to protect your information and use it only for the purposes we specify

6.3 Public Information

  • Your profile information (username, bio, display photo) may be visible to other users and publicly accessible via payment links and product pages
  • Blockchain transaction data is publicly available on-chain

6.4 Other Users

  • When you receive a payment, the payer may see your username and profile information
  • When you make a payment via a payment link, the recipient may see your username

6.5 Legal Requirements

  • When required by law, regulation, subpoena, or valid legal process
  • To respond to lawful government requests
  • To protect the rights, property, or safety of Chelotie, our users, or the public
  • To investigate fraud, security incidents, or violations of our Terms

6.6 Business Transfers

  • In connection with a merger, acquisition, bankruptcy, or sale of all or a portion of our assets
  • Users will be notified via email or Platform notice before any such transfer

7. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

  • Encryption of data in transit (TLS) and at rest
  • Secure password hashing (passwords are never stored in plaintext)
  • Regular security assessments and vulnerability monitoring
  • Role-based access controls and authentication measures
  • Secure communication channels with third-party service providers

No Absolute Guarantee: While we take security seriously and apply industry-standard safeguards, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

Your Responsibility:

  • Maintaining the security of your account credentials
  • Using strong, unique passwords for your Chelotie account
  • Never sharing your verification codes with anyone
  • Reporting suspicious activity to us immediately

8. Data Retention

We retain your information for as long as:

  • Your account is active
  • Necessary to provide our services
  • Required by applicable law, regulation, or legal obligations
  • Necessary to resolve disputes, enforce agreements, or establish legal defenses

When you delete your account, we will:

  • Delete or anonymize your personal information within 30 days, subject to legal retention requirements
  • Retain transaction records as required by law or for legitimate dispute resolution purposes
  • Instruct our Wallet Provider regarding your wallet data in accordance with their policies
  • Note: blockchain transaction data is permanent and cannot be deleted by any party

9. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

9.1 Access and Portability

  • Request access to the personal information we hold about you
  • Request a copy of your data in a commonly used, machine-readable format

9.2 Correction and Deletion

  • Update or correct your account information through your profile settings
  • Request deletion of your account and associated personal data
  • Note: Blockchain data and legally required records cannot be deleted

9.3 Opt-Out

  • Unsubscribe from marketing communications at any time via the unsubscribe link in emails
  • Note: You cannot opt out of service-related communications (e.g., verification codes, payment confirmations, security alerts)

9.4 Account Controls

  • Update your profile and account settings
  • Manage your products, payment links, and subscriptions
  • View your transaction history

To exercise these rights, contact us at: [Your Support Email]. We will respond to all valid requests within 30 days (or sooner where required by law).

10. International Data Transfers

Chelotie operates globally. Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. We take appropriate safeguards to ensure your data is protected in accordance with this Privacy Policy.

For users in the European Economic Area (EEA) and United Kingdom:

  • We rely on appropriate legal mechanisms for cross-border data transfers, including standard contractual clauses where applicable
  • You have additional rights under GDPR, including the right to object to processing and to lodge a complaint with your supervisory authority

11. Children's Privacy

Chelotie is not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us immediately at [Your Support Email] and we will promptly delete such information.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies for the following purposes:

  • Essential cookies: Required for authentication, session management, and platform security
  • Preference cookies: Remember your settings and preferences
  • Analytics cookies: Help us understand usage patterns and improve the Platform

You can control non-essential cookies through your browser settings. Disabling essential cookies may prevent you from using the Platform.

13. Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of any third-party sites. We encourage you to review the privacy policies of any third-party services you interact with.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

  • Post the updated policy on our Platform with a revised "Last Updated" date
  • Notify you of material changes via email or prominent Platform notice at least 15 days before the changes take effect

Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated policy, you must discontinue use of the Platform.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: [Your Support Email]
Address: [Your Business Address]

16. Regional Addendums

16.1 European Economic Area (EEA) and United Kingdom

Legal Basis for Processing:

  • Contract performance: Processing necessary to provide our services (account management, payment processing, wallet provisioning)
  • Legitimate interests: Platform improvement, security monitoring, fraud prevention
  • Legal obligation: Compliance with applicable financial and data protection regulations
  • Consent: Marketing communications and non-essential cookies

Your GDPR Rights:

  • Right to access, rectification, and erasure
  • Right to restrict or object to processing
  • Right to data portability
  • Right to withdraw consent at any time
  • Right to lodge a complaint with your local data protection authority

16.2 California, United States

CCPA/CPRA Rights:

  • Right to know what personal information is collected, used, and disclosed
  • Right to delete personal information (subject to legal exceptions)
  • Right to opt-out of sale of personal information — we do not sell your personal information
  • Right to correct inaccurate personal information
  • Right to limit use of sensitive personal information
  • Right to non-discrimination for exercising your privacy rights

17. Consent

By creating a Chelotie account and using the Platform, you consent to:

  • The collection, use, and disclosure of your information as described in this Privacy Policy
  • The provisioning and management of a wallet on your behalf by our Wallet Provider
  • The sharing of necessary data with our Wallet Provider and service providers to operate the Platform
  • The permanent recording of your transactions on public blockchains