Effective Date: 01.12.2025

This Privacy Policy («Policy») governs the collection, storage, processing, and protection of personal data in connection with the services provided by WWay Corp., a legal entity duly incorporated under the laws of Seychelles, under company number 247483, with offices located at: 306 Victoria House, Victoria, Mahé, Seychelles, a company operating under the brand «DeFi Club» («Club», «Company», «we», «us», or «our»), provides its services through the DeFi Club community platform, the official mini-application on the Telegram platform, and the official website: https://deficlub.pro/club/ («the Service»).

1. INTRODUCTION
1.1. By paying for a Subscription and becoming a User of the Service, you acknowledge that you have read and agree to the terms of this Policy. If you do not agree with any of its provisions, please discontinue using the Service.
2. DEFINITIONS
2.1. «User» – means any natural person who has purchased a Subscription to the Service or otherwise accesses or interacts with the Service’s materials, community, or communication channels, regardless of the level of activity or duration of participation.
2.2. «Subscription» – a paid access plan to the Service and its Content for a specified term, which may include different levels, providing access to specific resources, features, community privileges, or other benefits as described in these Terms.
2.3. «Administration» – means the authorized representatives of WWay Corp. responsible for managing the Service, processing Users’ data, and ensuring compliance with this Policy.
2.4. «Third Parties» – means any external service providers, payment processors, hosting operators, or other entities that may receive limited Personal Data from WWay Corp. strictly for the purposes defined in this Policy.
3. DATA WE COLLECT
3.1. You may provide us with certain information when using the Service or during Subscription-related activities, including:
a) Contact Information:
 (Full Name, Telegram ID, Telegram nickname, e-mail, phone number): used to identify the User, communicate with you, verify Subscription payments, and grant access to the Service;
b) Payment Information:
 transaction details required to process and confirm Subscription payments, including data received from the payment service provider;
c)Technical Data:limited information automatically provided by Telegram or connected services (such as IP address, device information, or access logs);
d) Other Information: may be provided voluntarily when communicating with the Service Administration. We do not recommend disclosing sensitive information in such communications and urge you to exercise caution when sharing data.
3.2. We may request additional information when required to comply with legal obligations, ensure payment verification, or maintain the security and proper functioning of the Service.
3.3. All collected data is used exclusively in accordance with this Privacy Policy and applicable laws. 3.4. We do not collect or process sensitive personal data, including information about racial or ethnic origin, political opinions, religious beliefs, health condition, or other categories of confidential information.

4.HOW WE COLLECT DATA
4.1. We obtain and process Users’ personal data through various methods, including both automated and manual information collection:

a)   Manual Data Entry by the User: the User may provide information directly to the Service Administration or within the Service community on Telegram, including during communication, support requests, or the Subscription process;

b)   Integration with Third Parties: we may use Third Parties when the User subscribes to or renews access to the Service, including but not limited to payment providers, strictly limited to the Personal Data necessary to verify Subscription payments and grant access to the Service.
4.2        All personal data is collected and processed exclusively in accordance with this Policy and applicable law, and solely for the purpose of providing, maintaining, and improving the functionality and security of the Service.

5.     USE OF DATA

5.1        We use the collected data to ensure the stable operation of the Service, improve the quality of the services provided, and for analytical and administrative purposes, including:

a)     Providing access to the Service’s materials, analytical content, and community functionalities;

b)     Facilitating communication and feedback with Users, including sending informational, organizational, and technical notifications related to the functioning of the Service and the delivery of services;

c)     Processing, verifying, and confirming Subscription payments, as well as resolving any related issues or disputes;

d)     Maintaining internal analytics and service improvement, including assessing engagement levels, optimizing communication channels, and enhancing the overall User experience.
5.2        The use of personal data is carried out strictly in accordance with this Policy and is limited to the purposes expressly stated herein.

6.     DATA STORAGE AND SECURITY

6.1        We implement organizational, technical, and administrative measures reasonably necessary to ensure the confidentiality, integrity, and protection of Users’ personal data, including:

a)     Location and Methods of Storage: personal data is stored in a protected MySQL database hosted on secure servers. The infrastructure operates under standard security protocols, with network-level protection provided through Cloudflare;

b)     Encryption and Access Control: access to the database and related systems is limited to authorized members of the Service Administration. Passwords and credentials are stored securely and are not shared with Third Parties;

c)     Data Retention Policy: personal data is retained only for as long as necessary to fulfill the operational and administrative purposes of the Service. Upon expiration of this period, or at the User’s justified request, the data is deleted from active storage.

6.2        While we take all reasonable precautions to safeguard Users’ data, no system of electronic storage or transmission can be guaranteed to be absolutely secure. The User acknowledges and accepts this risk and is advised to take independent measures to protect their own information, including securing access to their Telegram account and payment credentials.

7.     DISCLOSURE OF DATA TO THIRD PARTIES

7.1        We may disclose a limited amount of personal data to Third Parties only when such disclosure is necessary and strictly within the scope of their request. Any disclosure is restricted to the minimum amount of information required to perform the relevant processing activity.

7.2        In certain cases, we may share Users personal data with Third Parties, including:

a)     Payment Service Providers: for the verification and processing of Subscription payments and related settlements (e.g., transaction identifiers and payment confirmations);

b)     Technical and Infrastructure Providers: including Cloudflare and server hosting operators, to ensure the stable operation, functionality, and security of the Service’s services;

c)     Administrative Tools: such as internal spreadsheets or secure communication channels used solely for operational purposes within the Service Administration.

7.3        All Third Parties receiving Users’ personal data are required to comply with strict confidentiality obligations and to use such data solely for the purposes for which it was provided.
7.4        While we take all reasonable measures to cooperate only with reliable and compliant service providers, WWay Corp. shall not be held liable for any data breaches, unauthorized disclosures, or security incidents occurring on the side of such Third Parties, provided that we have not acted negligently in their selection or oversight.

8.     USERS’ RIGHTS AND DATA CONTROL
8.1        We provide Users with control over their personal data and the ability to manage it in accordance with applicable privacy standards and this Policy.
8.2        The options for managing personal data within the Service are limited by the technical capabilities of the platform and applicable legal requirements. Data management is carried out to the extent reasonably possible within the functionality of the Telegram environment and related systems. 8.3        Users may submit any requests or inquiries concerning the processing or deletion of their personal data to the Service Administration via the official contact channel through the Telegram: @deficlubsupport
8.4        All requests are reviewed within a reasonable timeframe, taking into account technical feasibility and applicable law.
8.5        We guarantee that any requests related to personal data will be handled with due regard for confidentiality and security. However, WWay Corp. reserves the right to retain certain information where necessary to comply with legal obligations, prevent fraud, resolve disputes, or enforce its rights under the applicable Terms of Use.

9.     AGE RESTRICTIONS AND RIGHT TO USE
9.1        The Service and its materials are intended solely for Users who are legally permitted to access and use them in accordance with the laws of their respective jurisdiction.
9.2        By paying for a Subscription and joining the Service, the User expressly represents and warrants that they:
a)     Have reached the age of majority and possess the legal capacity to use the Service materials in accordance with the laws of the country of which they are a citizen or resident;

b)     Comply with all applicable laws of their jurisdiction when accessing or using the Service materials.

9.3        We do not knowingly collect or process personal data of individuals who are not legally entitled to use the Service or its materials. If such a case is identified, WWay Corp. reserves the right to block the User, delete their data from the Service’s systems, and terminate access without refund, without prejudice to any other remedies available under the Terms of Use.

10.  CHANGES TO THE POLICY

10.1     WWay Corp. reserves the right to amend this Policy at any time in order to reflect updates in legislation, adjust data processing practices, or improve the operation of the Service.
10.2     Users are responsible for regularly reviewing the current version of this Policy. We are not obliged to provide individual notifications regarding any amendments.
10.3     The updated version of the Policy takes effect immediately upon its publication through the Service’s official communication channels. Continued participation in the Service community or use of the Service materials after such changes constitutes the User’s acceptance of the revised terms.

11.  GOVERNING LAW
11.1     This Policy shall be governed by and construed in accordance with the laws of the Republic of Seychelles, without regard to its conflict of law principles.

12.  DISPUTE RESOLUTION
12.1     In the event of any dispute, claim, or disagreement arising out of or in connection with this Policy, the Parties shall first seek to resolve the matter amicably through negotiation.
12.2     If the dispute cannot be resolved through negotiation, it shall be submitted to the competent courts of the Republic of Seychelles for final and binding resolution.

13.  CONTACT INFORMATION
13.1     If you have any questions or requests regarding this Policy or the processing of your personal data, please contact the WWay Corp. Administration via the official communication channel through the Telegram: @deficlubsupport