Evenkeel Capital LLC ("Evenkeel," "we," "us," or "our"), a Wyoming limited liability company with its registered office at 30 N Gould St, Ste N, Sheridan, WY 82801, United States, operates the Member Paywall platform, website, Telegram bots, and associated services (collectively, the "Service"). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the service.

Registered agent: Northwest Registered Agent Service Inc, 30 N Gould St, Ste N, Sheridan, WY 82801, United States.

1. Information We Collect

We may collect information about you in a variety of ways. The information we may collect via the Service includes:

Personal Data: Personally identifiable information that you voluntarily give to us when you register for the Service or when you choose to participate in various activities related to the Service. This includes:
- Your name and email address.
- Telegram user ID and username (for service functionality and communication).
- Information you provide when contacting customer support.
Financial Data: Financial information related to your payment method (e.g., valid credit card number, card brand, expiration date) is collected and processed by our third-party payment processor, Stripe, when you (as a Creator) set up payouts or when your subscribers make payments. We do not store full credit card numbers ourselves. We may receive transaction details (e.g., amount, date, last 4 digits of card) from Stripe for record-keeping and service provision.
Derivative Data (Usage Data): Information our servers automatically collect when you access the Service, such as your IP address, browser type, operating system, access times, pages viewed, and project configuration details. This helps us understand service usage and improve performance.
Data from Telegram: When you connect your Telegram account or use Telegram bots associated with our Service (e.g., @MemberPaywallBot or your project-specific Edge Bots), we collect necessary information to operate the Service, such as your Telegram user ID, username, and interactions with the bots (commands, messages related to service operation). This is essential for managing your account, projects, and subscriber access.

2. Use of Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Service to:

Create and manage your account and projects.
Process transactions (via Stripe) and send you related information, including purchase confirmations and invoices (if applicable).
Manage your subscriptions (if you are a subscriber) and your subscribers (if you are a Creator).
Provide customer support and respond to your inquiries.
Monitor and analyze usage and trends to improve your experience with the Service and develop new features.
Notify you of updates to the Service, security alerts, and support messages.
Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
Comply with legal obligations, such as tax reporting or responding to lawful requests from authorities.
Resolve disputes and enforce our agreements.

3. Disclosure of Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.
Third-Party Service Providers: We may share your information with third parties that perform services for us or on our behalf, including payment processing (Stripe), data analysis, email delivery (if applicable), hosting services, customer service, and technical support. These providers are authorized to use your personal information only as necessary to provide these services to us.
Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
With Creators: If you are a subscriber, we share your relevant information (e.g., Telegram ID, username, subscription status, payment confirmation details) with the Creator whose content you are subscribing to. This enables them to manage their subscribers, provide the services you paid for, and communicate with you. Creators are Data Controllers for their subscribers' data (see section below).
Aggregated/Anonymized Data: We may share aggregated or anonymized information that does not directly identify you with third parties for research, marketing, analytics or other purposes.

We do not sell your personal data to third parties for their marketing purposes.

Optional AI setup assistant (Anthropic): If a Creator chooses the optional AI setup assistant in our Telegram bot, the text they type to describe their channel and plans is sent to Anthropic, which processes it on our behalf to draft a suggested setup that the Creator reviews before anything is created. We do not send payment details, bot tokens, or subscriber data to Anthropic for this feature. Using the assistant is optional, and Creators can set up their projects without it.

4. Data Controller and Data Processor

Under applicable data protection laws, including the General Data Protection Regulation (GDPR) where it applies:

Creators as Data Controllers: If you are a Creator using our Service to manage subscriptions for your content, you are the "Data Controller" for the personal data of your subscribers that you process through our Service. You are responsible for complying with all applicable data protection laws regarding your subscribers' data, including having a lawful basis for processing and fulfilling their rights.
Evenkeel Capital LLC as Data Processor: When we process subscriber data on behalf of a Creator, Evenkeel Capital LLC (operating Member Paywall) acts as a "Data Processor." We process this data based on the Creator's instructions and our Terms of Service.
Evenkeel Capital LLC as Data Controller: For the personal data of Creators themselves (e.g., account information, usage data), Evenkeel Capital LLC acts as the Data Controller.

If you are a subscriber, the Creator of the content you subscribe to is the Data Controller of your personal data. We process your data as their Data Processor.

5. Security of Your Information

We use administrative, technical, and physical security measures to help protect your personal information. This includes measures like encryption, access controls, and secure server environments. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties.

6. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. Evenkeel Capital LLC is based in the United States. Your personal data may be processed by us or our service providers in the United States and other countries where our service providers operate. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. For Creators, account data is retained as long as the account is active and for a reasonable period thereafter for operational or legal reasons. Subscriber data processed on behalf of Creators is retained according to the Creator's instructions or until the Creator's account is deleted, subject to our backup policies and legal obligations.

8. Your Rights Regarding Your Information

Depending on your location and applicable data protection laws (including GDPR where it applies), you may have certain rights regarding your personal information. These may include the right to:

Access the personal data we hold about you.
Request correction of inaccurate personal data.
Request deletion of your personal data.
Object to or restrict processing of your personal data.
Request data portability (if applicable).
Withdraw consent (if processing is based on consent).

To exercise these rights, please contact us at [email protected]. If you are a subscriber and wish to exercise rights over data controlled by a Creator, you may need to contact the relevant Creator directly, though we will assist where appropriate.

9. Policy for Children

We do not knowingly solicit information from or market to children under the age of 13 (or 16 in certain jurisdictions, or 18 as per our Terms of Service for account creation). If you become aware that a child has provided us with personal information without parental consent, please contact us. If we learn that we have collected personal information from a child under the relevant age without verification of parental consent, we will take steps to delete that information as quickly as possible.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the bottom. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Contact Us

If you have questions or comments about this Privacy Policy, please contact us at: [email protected].

Last updated: October 8, 2026