Legal

Privacy Policy

Last updated: November 9, 2026

In short: we collect the minimum needed to run the service and comply with the law. We never access your seed phrase or private keys. We do not sell your data.

This English version is provided for convenience. If it differs from the Spanish version, the Spanish version prevails.

2. Data we collect

Account data: phone number or email address.
Network data: the TRON address you register and its public transaction history.
Device data: model, operating system, app version, device identifiers and IP address.
Usage data: number of free transfers used and activity within the app.
Identification data: only where anti-money-laundering rules require it (for example, name, ID document and tax ID).

We never collect your seed phrase or private keys.

3. How we use your data

To provide the Service: allocate network energy to your address and track your daily limit.
To prevent fraud, abuse of the free benefit and multiple accounts.
To comply with legal obligations on anti-money laundering and international sanctions.
To provide support and send you notices about the Service.
To improve the app using aggregated statistics.

4. Legal basis

We process your data with your consent, given when you register, and where necessary to provide the Service or comply with legal obligations. You can withdraw your consent at any time, without retroactive effect.

5. Who we share it with

Infrastructure, hosting, analytics and messaging providers acting on our behalf under confidentiality agreements.
Blockchain analytics and sanctions screening providers.
Competent authorities, such as the UIF, the CNV or the courts, when required by law.

We do not sell or rent your personal data.

6. International transfers

Some providers may store data outside Argentina. In those cases we require adequate levels of protection, in accordance with Law No. 25,326 and AAIP regulations.

7. Retention

We keep your data while your account is active and, after closure, for the periods required by applicable law, in particular anti-money-laundering rules. We then delete or anonymize it.

8. Security

We apply technical and organizational measures to protect your data, such as encryption in transit, access controls and monitoring. No system is completely infallible; if we detect an incident that affects you, we will let you know.

9. Your rights

You can exercise your rights of access, rectification, update and deletion at any time by writing to privacy@rafaga.app.

Access is free of charge when requested at intervals of no less than six months, unless you show a legitimate interest.
We respond to requests for rectification, update or deletion within 5 business days.

Argentina’s Agency for Access to Public Information (AAIP), as the supervisory authority under Law No. 25,326, has the power to handle complaints and claims regarding breaches of personal data protection rules.

10. Minors

The Service is not intended for anyone under 18. If we find that a minor has created an account, we will close it and delete their data.

11. Analytics and cookies

Our website and app may use cookies and analytics tools to measure performance and the effectiveness of our campaigns. You can disable non-essential cookies in your browser or device settings.

12. Changes to this policy

If we update this policy, we will publish the new version with its date. If the changes are significant, we will notify you in the app.

13. Contact

Ráfaga · privacy@rafaga.app