Privacy Policy

Introduction

This Privacy Policy explains how TOR.ENERGY, IE ("we," "us," or "our") collects, uses, stores, and shares information about you when you use the OMTOGETHER mobile application ("App").

We are committed to protecting your privacy and handling your personal data in a transparent and responsible manner.

Data We Collect

2.1 Account Data

• Email address (for registration and authentication)
• Authentication provider data (Google, Apple, or Telegram sign-in tokens)

2.2 Profile Data

• Username / display name (chosen by user)
• Avatar or profile image (if provided)

2.3 Usage Data

• Meditation session logs (duration, type, completion status)
• Streak and progress data
• Group participation records
• GME participation records
• Referral activity

2.4 Token and Wallet Data

• Internal OMTGc balance and transaction history
• Released OMTG balance and mint history
• TON blockchain wallet address (if connected via TON Connect)

Note: Blockchain wallet addresses and on-chain transactions are publicly visible on the TON blockchain by nature. We do not control the visibility of on-chain data.

2.5 Device and Analytics Data

• Device type, operating system, app version
• Session duration and feature usage patterns
• Crash reports and error logs

2.6 Communication Data

• Support emails sent to om@omtogether.app
• In-app chat or community messages (if applicable)

2.7 Push Notification Data

• Push notification tokens (with your consent)

How We Use Your Data

Data Sharing

We do not sell your personal data.

We may share data with:

• Infrastructure providers — cloud hosting, database, and analytics services that process data on our behalf under data processing agreements
• Blockchain networks — wallet addresses and transaction data are recorded on the TON blockchain, which is public and decentralized
• Legal authorities — if required by law, court order, or to protect our legal rights

Data Retention

Your Rights (GDPR)

If you are located in the European Union or European Economic Area, you have the following rights:

• Access — request a copy of your personal data
• Rectification — correct inaccurate or incomplete data
• Erasure — request deletion of your data ("right to be forgotten")
• Portability — receive your data in a structured, machine-readable format
• Restriction — request that we limit processing of your data
• Objection — object to processing based on legitimate interest
• Withdraw consent — withdraw consent for push notifications or analytics at any time

To exercise any of these rights, contact us at om@omtogether.app. We will respond within 30 days.

Note: We cannot erase data that has been recorded on the TON blockchain, as this is outside our control.

Data Security

We implement industry-standard security measures including:

• Encrypted data transmission (HTTPS/TLS)
• Encrypted data storage
• Access controls and authentication for internal systems
• Regular security reviews

No system is completely secure. In the event of a data breach affecting your rights, we will notify you as required by applicable law.

Cookies and Tracking

Our website (omtogether.app) may use:

• Essential cookies — required for the site to function
• Analytics cookies — to understand site usage (with consent)

You can manage cookie preferences through your browser settings.

Children's Privacy

The App is not intended for users under the age of 13. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, contact us at om@omtogether.app and we will delete it promptly.

International Data Transfers

Your data may be processed in countries outside your country of residence, including Georgia and countries where our infrastructure providers operate. We ensure appropriate safeguards are in place for such transfers in accordance with applicable data protection laws.

Third-Party Services

The App integrates with:

• Google Sign-In — subject to Google's Privacy Policy
• Apple Sign-In — subject to Apple's Privacy Policy
• Telegram Sign-In — subject to Telegram's Privacy Policy
• TON Connect — wallet connection, subject to TON Foundation's terms
• TON Blockchain — public decentralized network

We are not responsible for the privacy practices of these third-party services.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes through the App or by email. The date at the top of this document reflects the most recent update.

Contact

For privacy-related questions or to exercise your rights:

om@omtogether.app TOR.ENERGY, IE Saburtalo district, Bakhtrioni street, N 22, flat N75 Tbilisi, Georgia

How to Delete Your Account and Data

You can delete your OMtogether account and all associated personal data at any time using one of the following methods:

In-app deletion (recommended)

1. Open the OMtogether app
2. Go to Profile → Settings → Delete Account
3. Confirm the deletion

What gets deleted within 30 days:

• Your profile information (name, email, avatar, bio)
• Username and login credentials
• Practice history and session logs
• Token transaction history (off-chain)
• Group memberships and chat messages
• Push notification tokens
• Support communications

What we keep (and why):

• Aggregated, anonymised analytics — cannot be linked back to you
• Financial records required by law (tax/accounting) — retained up to 5 years
• Blockchain transactions on the TON network — these are public and permanent and cannot be deleted by anyone

Web request (alternative) If you cannot access the app, request deletion via our public form: https://omtogether.app/delete-account, or email om@omtogether.app with the subject "Delete my account" from the email associated with your account. We will process the request within 30 days.

Important: Account deletion is permanent. You will lose all unclaimed OMTGc points, streaks, and earned badges. Any on-chain OMTG tokens remain in your TON wallet — only the link between the wallet and your OMtogether profile is removed.