I Am A Member Privacy Notice

Version 1.0 | Effective 30 October 2026

1. Who we are

CX Solutions, a company registered in Jamaica, 14 Constant Spring Road, Kingston ("we"). Privacy contact: King H. Valentine, [email protected].

2. Two roles

• We are the data controller for your Platform account, Member Key purchases, the Games Hub, security records, and payments we collect.
• Each Client (the business or creator whose community you join) is the controller of its membership list and community. We process that data for the Client on its instructions. The Client's name is shown when you join.

3. What we collect

• Identity: your Telegram user ID, and your display name, which is used only as a label.
• Web version (when it launches): your email, or your Google, Apple or Telegram sign-in identifier.
• Membership and payments:
  • which communities you joined, your tier, dates, renewals and cancellations;
  • payment identifiers and status from Stripe, PayPal or Telegram Stars (and later WiPay or DimePay). We do not store card numbers.
• Activity: "last active" dates.
• Games Hub: games played, wins, chips and points (play money), leaderboard position.
• Community: posts, reports and moderation records in communities run on the Platform.
• Technical: IP address, device and browser data, bot and Mini App logs (secrets are removed from logs), and cookies (see the Cookie Notice).
• Planned AI features (not live): "Catch me up" summaries and local news would process group messages briefly and keep only short-lived digests. They will be opt-in for each group, and this notice will be updated before they start.

4. Why we use it, and our legal basis (Data Protection Act, 2020, s.23)

• Account, access, payments, renewals and the Member Key: performing our contract with you.
• Games Hub and leaderboards: contract.
• Security, fraud and cheat prevention, moderation: our legitimate interests.
• Service notices (renewals, failed payments, changes): contract.
• Marketing: only with your separate consent, which you can withdraw at any time (ss.9, 10).
• Accounting and tax: legal obligation.
• Automated decisions: none with legal or similarly significant effects (s.12). Cheat flags are reviewed by a person before anyone is suspended.

5. Who we share with

• The Client whose community you join: your membership and payment status, and your Telegram display name.
• Telegram; payment providers (Stripe, PayPal, Telegram; later WiPay and DimePay).
• Hosting and infrastructure:
  • Railway (application hosting, United States region);
  • Neon (PostgreSQL database, the United States);
  • Cloudflare (DNS and security, global network).
• Others: professional advisers, and authorities where the law requires.
• Visibility: other members can see your display name, posts and leaderboard position.
• We do not sell personal data.

6. International transfers

Your data is processed outside Jamaica, including in the United States. We rely on your consent at sign-up and on contracts that require equivalent protection (s.31).

7. Retention

• Account and membership data: while active, plus [2 years].
• Payment records: [7 years].
• Community posts: while the group exists, or until you delete them.
• Moderation records: [2 years].
• Games data: while your account is active, plus [12 months].
• Technical logs: [90 days].
• Backups: overwritten within [35 days].

8. Your rights

• Access: see your data and get a copy (s.6), within 30 days.
• Stop: stop processing or marketing (s.11); we reply in writing within 21 days.
• Correct or delete your data (s.13).
• Withdraw consent at any time (s.9).
• Complain to the Office of the Information Commissioner, at oic.gov.jm.
• Compensation (s.69).
• To use any of these rights, contact [email protected] or send /privacy in the bot.

9. Age

The Platform serves 18+ contexts at the Client's election. The 18+ label attaches to the group or use case a Client runs through our bot, not to every visitor. When a Client turns on 18+ mode for its group or use case, the bot asks you to confirm your age at that point. We record your answer, the group or use case and the date, and we keep that record while you are a member of that group plus [12 months]. If you do not confirm that you are 18 or older, you cannot join or use that group or use case. Groups that are not in 18+ mode are for people at least 13. We do not knowingly collect data from children under 13 (including under the US Children's Online Privacy Protection Act). If we learn we have, we delete it.

10. US, EU and UK users

• US: we honour state privacy rights to know, delete, correct and opt out. We do not sell or share data for cross-context behavioural advertising, and we honour Global Privacy Control.
• EU and UK: our legal bases are contract, legitimate interests, consent and legal obligation. You also have the rights to portability and restriction, and to complain to your supervisory authority.

11. Security and breaches

• How we protect data:
  • encryption in transit (TLS via Cloudflare);
  • secrets kept outside the code;
  • Telegram logins verified by signature (HMAC);
  • payment and other webhooks verified by signature;
  • access control, and two-factor authentication for admins.
• Breaches: if a breach affects you, we report it to you and the Commissioner within 72 hours (s.21).

12. Changes

We post new versions here and tell you about important changes.