> ## ⚠️ DRAFT — NOT LEGAL ADVICE > > **This template must be reviewed and finalized by a qualified attorney before any > real-money/public use.** It is a working draft only and does not yet constitute a > binding policy. See also the [End User License Agreement](EULA.md) and the > [Terms of Service](TERMS.md), which are likewise DRAFTs. # Privacy Policy This is a working draft of the Privacy Policy for the CS2 Arbitrage Bot ("the Software") by Practical Systems ("we", "us"). It is **not legal advice** and **must be reviewed by a qualified attorney** before use. ## 1. Local-first by design The Software is **local-first**. It runs on your machine, stores its data in a local SQLite database on your device, and forks its backend on loopback (`127.0.0.1`). Your API keys, Steam secrets, dashboard token, trade history, watchlists, license, and analytics **stay on your device**. We do not collect or have access to them in the course of normal operation. Secrets are read from your local, git-ignored `.env`; the desktop app stores the dashboard token in your OS keychain, not in plaintext. ## 2. What we do NOT collect by default By default the Software sends **no telemetry, analytics, or usage data** to us or any third party. There is no account login required to use simulation. The Software does not transmit your secrets, keys, or trade data off your device as part of its core function. ## 3. Opt-in error monitoring (telemetry), scrubbed Error monitoring (Sentry) is **strictly opt-in and disabled by default** (`SENTRY_ENABLED=false`). If — and only if — you enable it and provide a DSN, diagnostic error events may be sent to your configured Sentry project. Before any event is sent, a `beforeSend` scrubber **removes personally identifying and sensitive data**, including IP addresses, email addresses, Steam IDs, API keys/tokens, webhook/bot-token URLs, and dollar amounts. You control this entirely; leaving it off means no such data leaves your machine. ## 4. Opt-in notifications Notification channels (Discord, Telegram, email, desktop, ntfy) are **opt-in and off by default**. If you enable a channel, the Software sends the notifications you configure to the third-party service you chose (e.g. Discord, Telegram, your email provider, ntfy), using the credentials you supply. That data is then handled under **that third party's** privacy policy, not ours. We do not receive a copy. ## 5. Third-party marketplaces and APIs When you connect a marketplace or price API (CSFloat, Steam, Skinport, DMarket, Buff163, Bitskins, Waxpeer, CS.MONEY, Pricempire), the Software communicates directly from your machine with **that service** using your credentials. Your interactions with those services are governed by **their** privacy policies and terms, and you are responsible for reviewing them. ## 6. Payments and licensing Purchases are handled by our **Merchant of Record, Polar**, for both the one-time perpetual license and the monthly subscription (see the [EULA](EULA.md) for tiers). Payment and billing data — and applicable VAT/sales tax — are processed by **Polar** under its own privacy policy; we do not store your full payment details. A license issued to you is verified **offline** on your device against a baked-in public key; the verify path makes no network call. The optional `LICENSE_REVALIDATE_URL` re-check, if you configure one, is a soft, non-blocking call you control. [LAWYER REVIEW REQUIRED] — The data-processing relationship with Polar (and any required DPA and sub-processor list) must be confirmed and disclosed accurately by counsel. ## 7. Data retention and deletion Your local data persists on your device until you delete it. To remove it, delete the local database (default `data/bot.sqlite` or the desktop app's user-data directory) and your `.env`. Uninstalling the desktop app and clearing its user-data directory removes local app data. The Ledger and any tax/cost-basis worksheet are likewise stored locally and removed the same way. ## 8. Your rights and requests Depending on your jurisdiction you may have rights to access, correct, delete, or port personal data, and to object to or restrict certain processing. Because the Software is local-first, most such data is already on your own device and under your control; requests relating to data held by our payment processor (Polar) are subject to its policies. ## 9. Children The Software is not directed to children and should not be used by anyone under the age required to trade in their jurisdiction. ## 10. Changes We may update this policy; material changes will be communicated reasonably. Contact and data-subject-request details to be specified on attorney review.