XpactChannel
Legal

Privacy Policy

Last updated: 11 October 2026

1. Who We Are

Xpact is operated by XPNNTL LTD, a private limited company registered in England and Wales under company number 17493975, with its registered office at 128 City Road, London, EC1V 2NX, United Kingdom ("Xpact", "we", "us", or "our").

XPNNTL LTD is the controller of the personal data described in this policy. It is registered with the UK Information Commissioner's Office (ICO) under registration number C2050711.

Privacy contact: support@xpact.app

Our representative in the European Union

Under Article 27 of the EU General Data Protection Regulation ("GDPR"), our representative in the European Union is:

Dinara Muradova
Sandstrasse 154, 50127 Bergheim, Germany
di.muradova17@gmail.com

You may contact our representative instead of us about anything in this policy.

We have not appointed a data protection officer. Please send privacy questions and requests to support@xpact.app.

2. What This Policy Covers

This policy applies when you use the Xpact bot or the Xpact mini app in Telegram, visit xpact.app, use the Xpact dashboard, send feedback, or contact us.

Xpact shows lots published by auction houses and other auction operators, and links each one to its source. We do not run auctions, and we do not process bids or payments for auction items.

3. Personal Data We Process

Your Telegram account

You use Xpact with your Telegram account. When you start the bot or open the mini app, Telegram passes us your Telegram user ID, your first name and Telegram username, and your Telegram language. We store:

We do not receive your phone number, your Telegram contacts, or your messages in other chats. We do not store your last name or profile photo.

If you open the bot through a link with a code, for example from our Telegram channel, we store that code to understand which links bring people to Xpact.

Dashboard accounts with an email address

The Xpact dashboard is by invitation. If we invite you, we store:

You can connect Telegram to your dashboard account. The dashboard gives you a one-time code that works for 10 minutes, and the mini app sends it back with your Telegram sign-in. Your Telegram account and your dashboard account then become one account. We store only a hash of the code.

Required Telegram channel

After the first 30 lots the bot shows you, you need to be a member of our Telegram channel @xpact_official to go on using the bot. We keep a count of the lots the bot has shown you. Once you pass 30, the bot asks Telegram whether you are a member of the channel. Telegram also tells the bot when people join or leave the channel. We do not store whether you are a member: the bot remembers a yes for up to 10 minutes, then asks Telegram again.

Telegram account age check

New Telegram accounts are often used for spam and abuse. Telegram does not tell us when an account was created, so we estimate it from the Telegram user ID. We record each Telegram user ID we see and the day we first saw it. We keep them for as long as we run this check, and they are not deleted when you delete your account. If we estimate that an account is less than 7 days old, it cannot use Xpact unless we let it in, and we record that decision. If you think we got this wrong, email support@xpact.app and a person will review it.

Your feed, favourites, and reminders

To run the service, we process:

Activity sessions

When you sign in, we record a session with its start and end time, your IP address, and your device and app information (user agent). While you use Xpact, the app sends a short activity signal about once a minute, so we can see how long you actively use the service.

We delete activity sessions and signals 90 days after a session was last used.

Product analytics

We use PostHog, in its EU data region, to understand how Xpact is used: pages visited, features used (such as search, filters, favourites, and links to auction sources), your IP address, and your device and browser information.

PostHog never receives your name, Telegram username, or email address. Accounts of Xpact staff are not measured.

Location

If you choose Near me, your browser or Telegram asks for permission to share your location. We use the coordinates, rounded to about 10 metres, and the distance you pick to find lots nearby and to show the name of the area. Your device keeps the location, its name, and the distance for up to 7 days so you do not have to share it again (see the Cookie Policy). Location is optional; you can choose a city instead.

Feedback and support

If you send feedback or contact us, we process your email address, your message, its type, your account ID if you are signed in, your IP address, and a reference number. Feedback is forwarded to our team by email.

Auction listings

Lots shown on Xpact are published by auction operators. They may include the names of sellers, auctioneers, or other people where the operator has published them. We process this information to show lots and link to their source. If you appear in a listing and believe the information is wrong or should not be shown, email support@xpact.app with the Xpact link and the original link.

Technical and security data

When you use Xpact, our servers and providers process technical data needed to deliver and protect the service: IP address, time of requests, pages and API routes requested, browser and device information, and error, security, and rate-limit information.

4. Where Our Data Comes From

We receive personal data:

5. Why We Process Data and Our Legal Bases

Under the UK GDPR and the EU GDPR, we rely on these legal bases:

PurposeMain dataLegal basis
Create and run your accountTelegram ID, display name, language, settingsPerformance of our contract with you
Run dashboard accounts with an email address, and connect them to TelegramEmail address, password hash, invitation and password-reset links, connection codesPerformance of our contract with you
Check that you are a member of our Telegram channelTelegram ID, count of lots shown, channel membershipPerformance of our contract with you: membership is a condition of free access to the bot
Check the age of Telegram accountsTelegram ID, the day we first saw it, estimated account ageOur legitimate interest in preventing spam, fake, and abusive accounts
Provide the feed, favourites, search, and lot pagesAccount ID, feed settings, favourites, feed historyPerformance of our contract with you
Send reminders and service messages in TelegramTelegram chat ID, reminder settings, favouritesPerformance of our contract with you
Provide Near meCoordinates, distance, area nameYour request to use the feature, and your consent to share your location
Record activity sessions in the mini appSession times, activity signals, IP address, user agentOur legitimate interest in operating, securing, and improving Xpact
Record activity sessions on the websiteSession times, activity signals, IP address, user agentYour consent (Analytics)
Product analytics with full measurement on the websitePages, features, browser identifier, IP address, user agent, account numberYour consent (Analytics)
Anonymous counting on the website and in the mini appPage views and feature use, without identifying youOur legitimate interest in understanding how Xpact is used
Understand which links bring people to XpactThe start code in the link you openedOur legitimate interest in understanding how people find Xpact
Record which version of the Terms you acceptedTerms version and timePerformance of our contract and our legitimate interest in being able to show acceptance
Answer feedback and support requestsEmail, message, account ID, IP addressOur legitimate interest in answering you and improving Xpact, or our contract with you
Show auction listingsInformation published by auction operatorsOur legitimate interest in providing an auction search service
Deliver and secure the serviceIP address, request, error, and security logsOur legitimate interest in running a secure and reliable service
Establish, exercise, or defend legal claimsRelevant account, message, and log dataOur legitimate interest
Comply with the lawData required by a valid legal requestLegal obligation

Where we rely on consent, you can withdraw it at any time; this does not affect processing that took place before you withdrew it.

6. Who Receives Data

We share data only as needed for the purposes above:

RecipientWhat they do and the data involved
TelegramDelivers the bot's messages and runs the mini app inside Telegram. Telegram processes your account and messages under its own privacy policy as an independent controller.
Vercel Inc.Hosts the website, the dashboard, and the mini app, and processes request data such as IP address and browser information.
Hetzner Online GmbHHosts our main database in Germany.
Google CloudRuns the services that collect and update lots, our search index, and the storage that serves lot images, in Germany (europe-west3).
PostHog, Inc.Product analytics in its EU data region, as described in section 3.
CartoDB Inc. (CARTO)Supplies map styles and tiles. CARTO receives your IP address, browser information, and the map area requested when a map loads.
Plus Five Five, Inc. (Resend)Delivers emails from Xpact, such as forwarded feedback and invitation and password-reset emails, including the address, the message, and delivery data.
Cloudflare, Inc.Provides DNS for xpact.app. It answers the lookup of our address and does not receive your use of the site.
Auction operators and their image hostsWhen you open a lot at its source, the operator's website receives ordinary connection data such as your IP address and browser information.
Professional advisers and authoritiesOnly where reasonably necessary to obtain advice, protect rights, or comply with a valid legal requirement.

We have data processing terms with our service providers where the law requires them. We do not sell personal data, and we do not share it for advertising.

7. International Transfers

Our main database and our servers are in Germany. We are established in the United Kingdom. The UK recognises the European Economic Area as providing adequate protection for personal data.

Some providers, including Vercel, PostHog, CARTO, Google, Resend, Cloudflare, and Telegram, and their subprocessors, may process data in other countries, including the United States. Where the UK GDPR or the EU GDPR applies, we rely on an adequacy decision or the UK extension to the EU-US Data Privacy Framework where available, or on the EU Standard Contractual Clauses with the UK addendum, or the UK International Data Transfer Agreement.

Email support@xpact.app for information about the safeguard for a particular transfer.

8. How Long We Keep Data

DataHow long we keep it
Account, settings, favourites, feed settings and historyUntil you delete your account
Activity sessions and signals, including IP address and device information90 days after the session was last used
Product analytics events (PostHog)12 months
Links you opened at their source, filter use, and reminder records12 months, or until you delete your account if sooner
Feedback and support messages12 months after we have dealt with them
Terms acceptance recordFor the life of your account, then as long as needed to show acceptance if a claim arises
Invitation and password-reset linksA link works for 7 days or until used; the hash of it is kept until you delete your account
Telegram connection codesA code works for 10 minutes or until used; the hash of it is kept until you delete your account
Telegram user IDs, the day we first saw them, and decisions to let an account inFor as long as we run the account age check; they are not deleted when you delete your account
Count of lots the bot has shown youUntil you delete your account
Security and server logsUp to 30 days
Database backupsUp to 30 days before they are overwritten
Location on your deviceUp to 7 days
Sign-in token in the mini appUntil you close the mini app
Sign-in token on the website24 hours

When you delete your account, we delete your favourites, feed settings and history, reminders, links to your Telegram account, and your email address and password, and we anonymise the rest of your account record within 30 days. We may keep a minimal record where the law requires it, to show which Terms you accepted if a claim arises, or to prevent serious abuse. Data may remain in backups until they are overwritten.

9. Your Rights

Under the UK GDPR and the EU GDPR, you have the right to:

To delete your account, send /delete to the Xpact bot and confirm, or email support@xpact.app. To change cookie choices on the website, use Cookie settings in the footer. To stop reminders, change them in the bot's settings or send /pause. To stop sharing location, change the permission in your browser or Telegram.

For any other request, email support@xpact.app from the address you want us to reply to and tell us your Telegram username or Xpact account details so we can find your data. We may ask for a little more information to confirm the request is yours. We reply within one month, as the law requires.

You can complain to the UK Information Commissioner's Office (ico.org.uk). If you are in the EU, you can complain to the data protection authority in the country where you live or work, or where you think the problem happened. We would be grateful for the chance to resolve your concern first, but you do not have to contact us before complaining.

10. Children

Xpact is not for people under 18. We do not knowingly provide accounts to children. If you believe a child has given us personal data, contact support@xpact.app and we will delete it where appropriate.

11. Automated Decisions

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. The order and matching of lots in your feed are service features and do not decide anything about your rights.

The one automated refusal is the Telegram account age check in section 3: if we estimate that your Telegram account is less than 7 days old, Xpact refuses it automatically. Email support@xpact.app and a person will review the decision.

12. Security

We protect personal data with measures suited to an early-stage online service, including encrypted connections, access controls, signed sign-in tokens, rate limits, monitoring, backups, and limited access for staff. No online service is completely secure, so please keep your Telegram account and devices secure.

13. Other Websites

Xpact links to auction operators and other websites. Their privacy practices are governed by their own policies; please read them before you register, bid, or share information there.

14. Changes to This Policy

We may update this policy when Xpact, our providers, or the law change. The current version and its "last updated" date are always on xpact.app. If a change materially affects how we use your data, we will also tell you through the Xpact bot or on the website, and where new consent is needed, we will ask for it before the new processing starts.

15. Contact

XPNNTL LTD (trading as Xpact)
128 City Road, London, EC1V 2NX, United Kingdom
Email: support@xpact.app

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