Privacy Policy

SantaPass is operated by the SantaPass team (the “operator”, “we”, “us”). For any privacy-related request, contact us through the billing bot @SantaBillingBot in Telegram. We act as the data controller for signed-in owners and players who interact directly with SantaPass. When your organisation runs its own bot through SantaPass, we act as a data processor for the data your players submit inside that bot.

We collect only what we need to run a Secret Santa game and bill for the service:

• Telegram account data — your numeric Telegram id, first name, last name, @username, language code and public photo URL. Provided by Telegram when you press /start on a SantaPass bot or sign in to the cabinet.
• Google account data (optional, tenant-side only) — email, name and avatar. Collected only when a player without Telegram uses the web-based subdomain join and chooses “Continue with Google”.
• Game data — game name, budget, deadline, participant display names, wishlist text, Santa↔giftee chat messages, exclusion rules.
• Billing data — subscription tier, Telegram Stars charge id, payment timestamps. We do not see card numbers; Telegram processes the payment.
• Technical data — IP address, user agent, session cookie (for the cabinet), bot API logs and webhook delivery timestamps.

We use the data strictly to:

• deliver the Secret Santa service — create and match participants, deliver draw results, route wishlist updates to Santas;
• authenticate you on the cabinet and inside the Mini App;
• process subscription payments and issue receipts;
• prevent abuse, spam and fraud;
• respond to support requests and diagnose technical issues;
• comply with legal obligations (accounting, tax, law-enforcement requests).

We do not use your wishlists, messages or participant lists for marketing, AI training or any third-party analytics.

Under the EU General Data Protection Regulation we rely on:

• Contract (Art. 6(1)(b)) — to operate the bot, run the draw and keep your subscription active;
• Legitimate interest (Art. 6(1)(f)) — to secure the platform, prevent fraud and keep aggregate operational logs;
• Consent (Art. 6(1)(a)) — for optional integrations (e.g. Google sign-in) that you explicitly trigger;
• Legal obligation (Art. 6(1)(c)) — to retain billing records for statutory periods.

We share data only with the sub-processors that actually deliver the service:

• Telegram (Telegram FZ-LLC) — every bot message transits Telegram. See Telegram’s own privacy policy.
• Google — only if a player uses Google sign-in on a tenant subdomain.
• Cloud infrastructure providers — our hosting and CDN (currently Cloudflare).
• Payment processor — Telegram Stars (Telegram); we see only the charge id and the amount.

We never sell personal data. We may disclose data to law enforcement when required by a valid legal order in our jurisdiction of incorporation.

• Tenant data (bot record, games, messages) — for the duration of the subscription, then up to 30 days after cancellation, then deleted;
• Player profile — while at least one game in which the player participates is active; deleted 30 days after the last game closes;
• Billing records — retained for up to 7 years to satisfy tax and accounting obligations;
• Webhook / error logs — 90 days, then rotated out;
• Deletion requests — processed within 30 days; see section 8.

If you are located in the EU, the UK or a jurisdiction with similar rules, you have the right to:

• access the personal data we hold about you;
• rectify inaccurate data;
• erase your account and associated data (“right to be forgotten”);
• export your data in a portable format (JSON);
• object to processing based on legitimate interest;
• restrict processing while a complaint is reviewed;
• lodge a complaint with your local supervisory authority.

Signed-in users can act on most rights directly in the cabinet:

• Open Profile → Data & privacy and press Download my data to receive a JSON export.
• Use Delete my account on the same page to purge your profile. Bot owners must delete their bots first.

For any other request, DM us through the billing bot @SantaBillingBot. We respond within 30 days.

The cabinet uses a single first-party session cookie to keep you signed in. We do not embed third-party analytics, advertising SDKs or cross-site trackers on the marketing pages. The Telegram Mini App uses Telegram’s own initData scheme — no cookies are set by the Mini App.

SantaPass is not directed at children under 13 (or 16 in the EU). If you believe a minor has created an account, contact us and we will remove the data.

Our servers and sub-processors may be located outside the European Economic Area. When personal data is transferred abroad we rely on the European Commission’s Standard Contractual Clauses or an equivalent safeguard.

If we change this Privacy Policy we update the “Last updated” date at the top of the page and, for material changes, post a notice in the cabinet before the change takes effect.

Questions or requests: DM @SantaBillingBot on Telegram.