Privacy Policy

Last updated: May 24, 2026

1. Introduction

This Privacy Policy describes how Swarming Labs LTD ("Sparkling", "we", or "us") collects, uses, discloses, and protects information when you use Sparkling, a self-custody AI assistant operating within Telegram and accessible at sparklingbangladesh.com (the "Service").

This policy applies globally. By using the Service, you acknowledge and understand these practices. For users in Bangladesh, we adhere to general data protection principles and respect the provisions of the Digital Security Act, 2018, regarding the protection of personal data.

2. Data Controller

Swarming Labs LTD
Intershore Chambers, Road Town, Tortola
British Virgin Islands
Email: [email protected]

3. Information We Collect

3.1 Information You Provide

• Account information: Telegram identifier, username, email address.
• Authentication credentials: One-time passwords (OTP) for wallet recovery (we do not store these in a retrievable format).
• Identity verification: Government ID, proof of address, date of birth, or biometric verification (processed by a licensed third-party provider, if legally required).
• Communications: Messages sent to Sparkling, trade instructions, and support requests.

3.2 Information Collected Automatically

• Transaction data: Swap quotes, signed transactions, agent strategy executions, and on-chain transaction hashes.
• Technical data: Device type, operating system, Telegram client version, IP address (retained for a maximum of 30 days unless required for fraud investigation), and approximate geographic region.

4. How We Use Your Information

• To provide the Service: Routing instructions, executing transactions, and displaying balances. (Legal basis: Contract performance).
• To authenticate and secure your account: Verifying logins and detecting suspicious access. (Legal basis: Contract performance and legitimate interest in account security).
• To prevent fraud and abuse: Detecting bots, market manipulation, and account takeovers. (Legal basis: Legitimate interest and anti-money laundering obligations).
• To comply with legal obligations: Responding to regulators, courts, and law enforcement agencies. (Legal basis: Legal obligation).

We do not use your information for marketing purposes without explicit opt-in consent. We do not sell your personal data.

5. Information Sharing

We share information with third-party vendors, including cloud infrastructure providers, email services, analytics providers, and identity verification providers. Each vendor is bound by a written data processing agreement. We may disclose information to comply with the law, regulation, legal process, or lawful government requests.

6. Your Rights

You have the right to request access to, correction of, or deletion of your personal data. To exercise these rights, please email [email protected]. We will respond within 30 days.

7. Security

We implement technical and organizational measures to protect information against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure, including TLS 1.3 encryption in transit, encryption of sensitive data at rest, and regular external security audits. Crucially, we never request or store your private keys.

8. Changes to This Policy

We may update this Policy. Material changes will be notified at least 30 days before taking effect. The "Last updated" date above reflects the current version.

9. Contact Us

General privacy inquiries: [email protected]