Privacy Policy

Last updated: August 2, 2026

1. General​

This policy describes how AdaptGroup LLC, a Wyoming limited liability company (hereinafter — the "Company"), processes data in connection with the AdaptGroup platform (hereinafter — the "Platform"). The policy applies to all Platform users — partners working through the dashboard, as well as end users of products launched on the Platform.

This policy informs users about data processing in connection with the Platform. Where applicable law requires consent, the Company requests it through a separate user action.

2. Partner Data​

2.1 Registration and Account​

The following data is collected upon registration:

• Email — when registering via email or Google/Yandex authorization
• Google or Yandex account — when signing in via the corresponding OAuth provider (only the necessary minimum is shared: name, email, account identifier)
• Telegram account — Telegram ID and username when linking the account

2.2 Platform Usage​

During dashboard usage, the Company collects:

• active session data (IP address, device, sign-in date)
• financial transaction history (top-ups, withdrawals, transactions)
• data on integrations and connected modules

2.3 Identity Verification​

When completing KYC, personal and biometric data is processed through Didit. The categories of data, purposes of verification, access, retention, and deletion are described in the Policy on the Processing of Personal and Biometric Data During KYC.

3. End User Data​

3.1 VPN Bots and VPN API Module​

When an end user's device connects to the VPN, the Company stores:

• hwid — hardware device identifier
• user_agent — client application identification string
• device_os — operating system
• device_model — device model
• os_version — operating system version
• ip_address — IP address at the time of the subscription request

Destination IP addresses (where the user connects through VPN) and traffic content are not analyzed or stored by the Company.

3.2 Support Bots Module​

Within the support bots module, the Company stores correspondence between operators and end users. Correspondence is not deleted automatically. Upon user request, data deletion is possible — contact support to do so.

4. Third-Party Data Sharing​

The Company does not sell or share user data with third parties, except where necessary for service operation:

• Payment systems — when processing payments, the minimum set of data required to create a payment is shared
• Hosting providers — the platform's server infrastructure is hosted by third-party providers; data is physically stored on their servers, however access to it by providers is not provided for under the hosting terms
• Didit — data necessary for identity verification is transferred when the user completes KYC; details are provided in the specific policy

5. Analytics​

The Company uses Google Analytics to collect aggregated traffic statistics for the dashboard and documentation. The collected data is anonymous and does not allow identification of a specific user.

6. Data Storage​

The Platform's primary data is stored on a dedicated server in Germany. The Company takes technical and organizational measures to protect data from unauthorized access.

7. User Rights​

Users have the right to:

• request information about stored data
• request deletion of their data

To exercise these rights, contact support through Telegram or at [email protected]

Please note that the self-service data deletion feature through the dashboard is currently under development.

8. Policy Changes​

The Company may amend this policy. The current version is published in the Platform documentation. Continued use of the Platform after changes take effect constitutes acceptance of the updated policy.

9. Contact​

For questions related to personal data processing, contact us through Telegram or at [email protected]

Company Details​

AdaptGroup LLC
30 N Gould St Ste R
Sheridan, WY 82801, USA