Privacy Policy for Bogeme Platform

1. Data Controller

During the testing and infrastructure evaluation phase, the data controller is the operator of the BOGEME software project.

• Project Entity: BOGEME Software Project Operations Team
• Status Notice: A registered corporate legal entity and its designated statutory jurisdiction will be formally updated here upon commercial production launch.
• Privacy Inquiries & Data Rights Requests: support@bogeme.com
• Exercise Your Rights In-App: You can request a machine-readable copy of your data, record an age attestation, and submit a permanent erasure request from Settings, and view legal contact points, statement-of-reasons decisions and the complaint/appeal procedure on the Legal page (/legal). An erasure pseudonymises your identity in place while retaining the transaction and wallet records the platform is legally required to keep.
• EU Representative (GDPR Article 27): As the Platform currently has no establishment within the European Union and processes personal data of data subjects in the EEA, an authorized EU representative will be formally designated and named in this section upon commercial production launch. Until that designation is made, privacy and data-rights inquiries should be directed to support@bogeme.com.

2. Data We Collect and Lawful Bases for Processing

We minimize data collection to what is required to operate the Platform securely. We process data under Performance of a Contract and Legitimate Interests. Optional browser storage used for referral backup is activated only with your consent via our cookie banner. Referral attribution recorded in our database from the registration URL is part of providing the referral program and does not depend on that optional storage.

2.1. Information Required to Operate the Platform (Performance of a Contract)

To execute the core functionalities of the Platform and service agreements between Creators and Subscribers, we must process the following data:

• Account Profile: Your email address or social media login identifier provided during Web3 hybrid authentication. This data is stored in our centralized PostgreSQL database to manage your profile records, user badges, notification preferences, and internal account IDs.
• Creator Content and Activity: Blog posts, fundraising goals, promotional activities, and subscription statuses that you publish or interact with.
• Text-to-Speech (TTS) Payloads: When utilizing automated voice generation or fundraising audio utilities, text payloads are processed through our independent text-to-speech engine (piper-tts). The resulting audio output is temporarily cached and stored on our media servers strictly to execute the on-demand technical rendering of the requested content.
• Blockchain Records: Your programmatically generated Base blockchain wallet address (Smart Account / ERC-4337 architecture), spending limits, on-chain session keys established for subscription automation, and platform transaction hashes.

2.2. Technical and Security Logs (Legitimate Interests)

To maintain infrastructure stability, enforce security, and prevent transactional fraud, we log technical telemetry data:

• Anti-Bot Telemetry: Your Internet Protocol (IP) address, request timestamps, and device connection attributes collected in real-time via integrated edge security scripts (Cloudflare Turnstile).
• Internal Activity Tracking: Our backend platform captures and retains your IP address inside structural logging tables (such as post_reads). This is used strictly to calculate unique blog read counters, deliver internal notification logs, and prevent sybil manipulation of view metrics.
• Registration IP Address: The Platform stores the IP address captured at the moment of your initial account registration (registration_ip) as part of your account profile. This is processed under our legitimate interest in security, including sybil detection, multi-accounting prevention, and referral abuse prevention. Retention limits are described in Section 4.
• Administrative Actions: Records of profile-level sanctions, including database indicators for platform-wide bans (account_banned), interface restrictions (interface_blocked), messaging locks (chat_banned), and content visibility suppression (blog_mode_banned).
• Direct Messages & Chat History: We store user-to-creator chat logs natively within our database backend. Please note: Messaging channels on the Platform are NOT end-to-end encrypted (E2EE). Text content and media captions are stored as unencrypted plain text to allow our server to process Text-to-Speech requests and to enable manual safety reviews by our moderation team upon user abuse reports.

2.3. Referral Attribution and Optional Storage

If you register via an affiliate link, we read the referral parameter from the URL at registration and store the attribution in our database so we can apply the referral program. This database record is required to operate the referral feature. Separately, if you give consent via our cookie banner, we may also store a referral marker in your browser local storage (bogeme_referral_code) as a backup for cross-session attribution. This local storage marker is optional, off by default, and can be withdrawn at any time via Cookie Settings.

3. Third-Party Subprocessors and Transfers

To deliver the BOGEME software ecosystem, specific technical subsets of your data (such as IP addresses, technical metadata, and login records) are shared with the following infrastructure providers:

• Dynamic.xyz (USA): Our non-custodial Web3 authentication engine, managing secure cryptographic entry vectors and decentralized account initialization.
• Cloudflare Turnstile (USA): Our edge security layer, analyzing browser attributes in real-time to defend our systems from bot networks and malicious scripts.
• Alchemy Insights, Inc. (USA): Our blockchain RPC node provider. It processes transaction payloads to read and write states to the Base blockchain network.
• Pimlico (Pimlico Technologies Ltd, UK): Our Account Abstraction infrastructure. Pimlico operates as our ERC-4337 Bundler and Paymaster, processing programmatic transaction user operations to execute interactions where the network gas is paid in USDC through the paymaster, rather than requiring you to hold native ETH, and to perform session-key subscription renewals.
• Cloud Hosting Providers: Our centralized PostgreSQL database, media caches, and self-hosted piper-tts engine run on managed server infrastructure. During the current testing and infrastructure-evaluation phase, this infrastructure operates in a non-production environment, and the definitive hosting region has not yet been finalized. Upon commercial production launch, the Platform's primary data store and media caches are targeted to be hosted within European Union data centers under GDPR-compliant processing agreements; the confirmed hosting region and applicable processing arrangements will be stated in this Policy at that time.
• International Data Transfers: Because our primary technology subprocessors are located in the United States and the United Kingdom, your technical connectivity logs (including IP addresses and account email identifiers) are transferred outside the European Economic Area (EEA). The Platform is currently in a non-production testing phase, and formal data-processing and cross-border transfer agreements with these providers have not yet been executed; upon commercial production launch, such transfers will be placed under appropriate safeguards required under applicable law, including Standard Contractual Clauses approved by the European Commission or equivalent mechanisms.

4. Data Retention and Immutability

We retain information within our centralized PostgreSQL database only for as long as necessary to fulfill operational safety and contractual services:

• Active Life Cycle: Profile parameters, creator posts, and chat logs are stored for the duration of your active account lifespan.
• Account Deletion: Upon processing an explicit account deletion request, your account is immediately frozen - all platform features are blocked. Your profile metadata, text-to-speech audio caches, and chat logs will be permanently wiped from our central cloud servers after 30 days. However, if you have active subscriptions (paid access periods that have not yet expired), your account deletion is deferred until all such subscription periods have ended, ensuring subscribers receive the content access they paid for. You may cancel the deletion request at any time before physical deletion occurs to restore full access.
• Security Logs & IP Tracking: Operational server logs, IP records in tracking metrics (post_reads), and anti-bot metadata are overwritten or deleted after 180 days.
• Registration IP Address: The IP address captured at initial registration (registration_ip) is retained for the life of your account. After account closure or permanent ban, we may keep it for up to 24 months where necessary to enforce bans, prevent sybil attacks, and detect referral system abuse. It is not used for marketing and is not subject to the routine 180-day activity log deletion cycle. Where you request erasure, we will delete or anonymize this field unless we must retain it for these security enforcement purposes.
• Moderation & Safety Records: If an account is banned or restricted for violating our Terms of Service, we retain the structural database records, associated email identifiers, and public wallet addresses for as long as necessary for enforcement purposes within our central PostgreSQL ledger. This continuous retention is strictly necessary under our legitimate interest to prevent bad actors from circumventing platform bans and re-registering malicious accounts.
• Blockchain Immutability Exception: You explicitly acknowledge that data finalized and written to the public Base blockchain ledger (such as subscription states, transaction hashes, and session key deployments with specific spending limits) cannot be altered, deleted, or removed by us under any circumstances.

5. Cookies and Local Storage Technical Matrix

The Platform deploys data storage elements into two distinct categories in full alignment with global compliance standards:

Optional components are strictly deactivated by default. These components are initiated only after you provide affirmative, unambiguous consent via our Interface banner. You maintain an unrestricted right to withdraw your consent at any time by accessing your browser settings or using the Cookie Settings interface link in our footer.

6. Children's Privacy Rules

BOGEME is strictly designed for an adult creative, technical, and mature audience. We do not knowingly collect, log, or maintain any personal data from individuals under the age of 18. If we discover that an individual under 18 has registered an account or provided an email address, we will instantly and permanently delete all associated files from our PostgreSQL servers.

7. Your Privacy Rights and Compliance

7.1. For European Union and EEA Citizens (GDPR)

You possess the following statutory rights regarding your personal information:

• Right to Access & Portability: You can request a digital copy of the personal data we store about you in our centralized PostgreSQL database.
• Right to Rectification & Erasure: You can demand the correction or permanent deletion of your profile parameters and email logs from our systems. Please note that data written to the public blockchain ledger cannot be erased (see Section 4: Blockchain Immutability Exception).
• Right to Restriction & Objection: You can object to our processing of technical server logs or request that we pause processing your data.
• Right to Withdraw Consent: You can opt-out of functional cookies or tracking markers at any time via Cookie Settings in the footer or by contacting support@bogeme.com.
• Right to Lodge a Complaint with a Supervisory Authority: Under Article 77 GDPR, you have the right to lodge a complaint with a supervisory authority - in particular the supervisory authority of your habitual place of work, residence, or place of the alleged infringement - if you consider that our processing of your personal data infringes the GDPR.

To exercise these rights, submit an email request to support@bogeme.com for data access or rectification. For account deletion, use the self-service deletion feature in your account settings (Settings: Account Deletion). We are legally required to verify your identity before releasing data. We will provide a comprehensive response within 30 days of receiving your request.

7.2. For California Residents (CCPA/CPRA)

• No Sale or Sharing of Data: BOGEME does not sell, rent, or share your personal data, email addresses, or transaction histories with third-party data brokers or marketing networks for commercial gain. We do not sell or share personal information as defined by the California Privacy Rights Act (CPRA).
• Categories Collected: Identifiers (Email, IP address, Crypto wallet hash), Internet network activity logs.
• Right to Know & Delete: You have the right to request disclosure of what data we collect and request its total removal.
• Non-Discrimination: We will never deny services, change rates, or provide lower-quality interfaces if you choose to exercise your privacy choices.

8. System Changes and Language Precedence

• 8.1. Right to Modify: We reserve the right to amend this Privacy Policy at our sole discretion. Any changes will be published on this page with an updated "Last Updated" timestamp.
• 8.2. Language Precedence: This Policy is executed, applied, and interpreted strictly in its English language version. Any translations provided are done solely for reading convenience and hold no legal authority over the English original.