Privacy policy

This Privacy Policy explains how Velvary Entertainment Ltd. ("the Company", "we", "us") processes the personal data of users of the velvary.vip website and its associated Telegram bot (the "Service"). We process data in accordance with the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the Maltese Data Protection Act.

1. Data Controller

The controller of your personal data is:
Velvary Entertainment Ltd.
Reg. No.: C 98765 · VAT: MT 2345 6789
Address: Level 2, Palazzo Vella, 81 Triq San Pawl, Valletta VLT 1213, Malta
Email: support@velvary.vip

2. Data We Collect

• Account data: your email address and a password stored as an irreversible cryptographic hash (bcrypt).
• Telegram data: if you sign in via the bot — your Telegram ID, username and first name.
• Conversation content: the messages you exchange with AI companions and derived data (conversation summaries, memory facts for the companion).
• Technical data: IP address, browser and device type, date and time of requests, session cookies.
• Payment data: payments are processed via Telegram Stars; we do not receive or store card details.

3. Purposes and Legal Bases

• Providing the Service and powering conversations with AI companions — performance of a contract (Art. 6(1)(b) GDPR).
• Security, fraud and abuse prevention — legitimate interest (Art. 6(1)(f)).
• Sending service messages (e.g. password reset) — performance of a contract.
• Marketing messages — only with your explicit consent (Art. 6(1)(a)), which you can withdraw at any time.
• Legal compliance, including age verification — legal obligation (Art. 6(1)(c)).

4. Sharing With Third Parties

We do not sell your personal data. We engage service providers (processors) acting on our behalf: an AI inference provider to generate responses, a hosting provider, an email delivery service and Telegram's payment infrastructure. Each is bound by a data processing agreement. Where data is transferred outside the European Economic Area, EU Standard Contractual Clauses apply.

5. Data Retention

Account and conversation data is retained while your account is active. After you delete your account, data is erased or anonymised within 30 days, except where we are legally required to retain it (e.g. for accounting purposes).

6. Your Rights

Under the GDPR you have the right to access, rectify, erase, restrict processing of, port and object to the processing of your data, as well as to withdraw consent. To exercise these rights, contact us at support@velvary.vip. You also have the right to lodge a complaint with the supervisory authority — the Information and Data Protection Commissioner of Malta (IDPC).

7. Age Restriction

The Service is intended exclusively for adults aged 18 and over and contains adult content. We do not knowingly collect data from minors. If we become aware that an account belongs to a person under 18, it will be deleted.

8. Cookies

We use strictly necessary cookies for authentication (session), remembering your chosen language and abuse protection. They are not used for third-party advertising tracking.

9. Security

We apply technical and organisational safeguards: traffic encryption (TLS), password hashing and restricted access to data. No method of transmission is completely secure, but we strive to protect your data using the best available means.

10. Changes to This Policy

We may update this Policy. The current version is always available on this page with its update date.

11. Contact

For any privacy questions, email support@velvary.vip or reach us in the Telegram bot @Velvary1bot.