Privacy Notice

1. Data controller

The controller for personal data processed by Cluster is Solovei Kyrylo, ninepeaks, Rue de la Croix-Federale 27, 2300 La Chaux-de-Fonds, Switzerland. Data protection contact: dwzzd@icloud.com. This Notice describes personal data processing in connection with Cluster.

2. Data categories and purposes

Account creation and security involve the username, email address, password hash, email confirmations, two-step authentication settings and sign-in sessions. Technical logs may contain the IP address, request time and request information. These data support access, abuse prevention, diagnostics and service security.

Connecting Telegram involves the phone number, Telegram ID, application credentials, stored authorization session and events required by enabled features. Personal bot tokens and proxy settings are processed when supplied. The Telegram password is not retained. Service secrets are stored in an encrypted database; encryption does not prevent operational processing by the running service.

Module data, files, configuration, logs and backups are processed to operate the module. A module may receive authorized messages and store information from them in its own data or logs. The absence of a separate core chat archive therefore does not mean that user-installed modules never retain message content.

Social features process the display name, biography, images, publications, friend relationships and visibility settings. A verification request includes a category, explanation and supplied links. Application content and the administrator's comment are available to the applicant and administrators; the verification badge itself is visible in the profile and search results.

3. Purposes, legal grounds and access

Processing supports contract formation and performance, security and legitimate interests in maintaining the service, legal obligations, and consent where required. Where EU data protection law applies, the relevant grounds include contract performance, legitimate interests, legal obligations and consent as appropriate to the specific purpose.

Profile fields are disclosed according to visibility settings; usernames, display names and verification status are available to signed-in users. Public publications remain in the catalog even when the profile publication list is hidden. Modules receive data through permitted core methods within accepted permissions. Network permission granted by the user may allow a module to disclose received data to third parties.

Administrative investigation provides limited temporary read-only access to Cluster logs, module records, configuration and file metadata. It does not provide Telegram session chat history, file contents or a terminal. Secret fields are hidden; the investigation reason and requests are retained in a separate audit log for 30 days. Broader technical support access requires separate user authorization.

4. Recipients and international processing

The service uses netcup infrastructure, Telegram and Stripe. The primary Cluster server and mail service are hosted in Germany by netcup. Telegram processes information transmitted through the connected account or bot. The website loads the official Telegram Mini Apps script, which sends Telegram the browser IP address and technical request information. Stripe receives information required for payment; Cluster retains customer, subscription and transaction identifiers, amounts and statuses. Full card details are entered on Stripe's page and are not received by Cluster.

Third-party providers may process data in the EU, the United States and other jurisdictions described in their notices. International disclosures are subject to applicable requirements concerning adequacy, contractual safeguards or other permitted grounds. Email recipients also use their own email providers. Further information about a specific disclosure may be requested from the controller.

5. Retention and deletion

Data are retained for the relevant feature and processing purpose. Users can delete working data; log, file and backup retention depends on their settings. Working data remain for 30 days after suspension for subscription expiry. Account deletion has a seven-day cancellation period, after which profile settings, verification applications and related profile decision records are removed.

Payment and correspondence records may be retained separately to the extent and for the period required for accounting, legal obligations and the handling of claims. Removal from active systems does not imply immediate removal from all backups. Data retained by law or for dispute resolution are restricted to that purpose.

6. Cookies, links and individual rights

The website uses necessary authentication cookies, CSRF protection and local language and interface settings. Advertising analytics is not installed. External links lead to sites governed by their own terms. Images embedded in Markdown biographies are not automatically loaded.

Subject to applicable law, individuals may request access, a copy, correction, deletion, restriction or portability of their data, or object to processing. Consent may be withdrawn prospectively without affecting prior lawful processing. Requests should be sent to dwzzd@icloud.com; proportionate identity verification may be required. Individuals may complain to the competent supervisory authority, including the FDPIC in Switzerland.