Privacy Policy

This Privacy Policy (“Privacy Policy”), is an integral part of our (“EULA”) and governs the processing and transfer of personal data collected or processed. (“Company”, “we”, “us” or “our”) when you access or using our mobile application or our services, all as detailed in the applicable EULA (respectively the “App” and “Service”).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the EULA.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

In the event, you are a California resident and the CCPA applies to you – please also review.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us

This Privacy Policy explains our data collection practices that apply to any users of our App or our Services (“you” or “your”).

To operate our Services and App, we use several service providers as detailed in this Policy (collectively “Service Providers”):

• In-app payment providers;
• Advertising partners;
• Fraud prevention and analytic tools; and
• Tracking tools.

We contractually ensure our Service Providers comply with applicable data protection laws.

Video Chat

App video chat service requires a direct connection to be made between your device and the other user's Devise. To do this, it is necessary to make your IP address available to the other user's Devise, although it is not shown to the other user by App's interface. This is a necessary part of how any P2P video chat system functions. If you are not comfortable with this, use text mode instead.

1. OVERVIEW OF THE INFORMATION WE PROCESS FROM YOU

We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, session duration and page impressions, etc.

The second type of information is identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

erience.	Our partners will process this data to manage and deliver advertisements more effectively and personally, including contextual, behavioral, and interest-based advertising based on your activity, preferences, or other data available to us or to our business partners and advertisers, including for re-targeting purposes.	We process this information based on your consent as required under your jurisdiction provided through our cookie manager or similar technologies.
Technical Data: We also collect certain technical Non-Personal Data which relates to your use of our Apps such as the type and version of device, application, or browser used, operating system, or time zone setting, country, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs.	We use this data to maintain, support, improve, protect and manage our App and Services. This information does not include Personal Data.	As the technical data is Non-Personal Data it does not require a lawful basis.

In addition to any information contained in a Saved Chatlog, within the last twelve (12) months, We have collected the following categories of personal information from the following sources and disclosed it for a business purpose to the following third parties:

Category	Examples	Source	Disclosed With
A. Identifiers.	Online identifier (an ID cookie assigned when you first log into App); and Internet Protocol address.	You	Service Providers, other users if you use video chat services, and may be disclosed to law enforcement.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	College domain name only if you use college mode.	You	Service Providers and other users if you both are using college mode.
C. Protected classification characteristics under California or federal law.	NONE
D. Commercial information.	NONE
E. Biometric information.	NONE
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	You	Service Providers; and may be disclosed to law enforcement.
G. Geolocation data.	Country-level geolocation, based on IP address, is used for safety and security purposes.	You	Service Providers.
H. Sensory data.	Visual snapshots of video stream chats are taken for moderation.	You	Service Providers, including moderation service providers; may be disclosed to law enforcement.
I. Professional or employment-related information.	NONE
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	NONE
K. Inferences are drawn from other personal information.	NONE

2. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the App and Services, we may collect information as follows:

2.1. Automatically – we may use SDK (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our App and Services.

2.2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Services, contact us communications, etc.

3. SHARING DATA WITH THIRD PARTIES

We will not share your Personal Data with third parties, other than as specifically mentioned herein:

• Subject to your consent - we may share your Personal Data upon your explicit consent. Once we share your Personal Data under these circumstances, that data becomes subject to the other third party’s privacy practices.
• Policy enforcement and third party rights - we may share your Personal Data in the event required to enforce our policies and agreements or to establish and exercise our rights to defend against legal claims, including investigations of potential violations, and to, detect or prevent illegal activities or other wrongdoing, security or technical issues. In addition, we may share your Personal Data to prevent harm to the rights or safety of our users or any applicable third party.
• Law enforcement - we may share your Personal Data, solely to the extent needed to comply with any applicable law, regulation, legal process, or governmental request.
• Affiliate company and corporate transaction – in the event required, we may share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under a common control (“Affiliated Companies”) or in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). Our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Policy.
• Service Providers - we may disclose Personal Data to our service providers to perform requested services on our behalf. Certain of our service providers shall include servers, payment processors, advertisement services, governmental agencies, and representatives. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services and are all signed on applicable data protection agreements limiting their use of Personal Data.

Use of Personal Information

We may use, or disclose the personal information App collects for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, to provide the chat service.
• To help maintain the safety, security, and integrity of App and chat services. For example, the App may screen and use the information to protect against spammers, hackers, and others who pose harm to the site and services; App may share information with moderation service providers, and App may share the information with law enforcement.
• To evaluate and improve the site and services. For example, App may aggregate and/or de-identify information to produce statistical data such as the average number of chats started at different times of the day.
• To monitor and enforce user compliance with App's Guidelines and policies. For example, Our App may share information with its moderation service providers; use automated systems to screen information for suspicious activity, and share the information with law enforcement.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of App's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by App about our site and services users is among the assets transferred.

Sharing Personal Information

We may disclose your personal information to a third party for business purposes. When We disclose personal information for a business purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In addition to the service providers identified in the Cookie Section above, App uses Linode for hosting services, AWS for Saved Chatlog storage services, and Cloudflare for content delivery network services. Please click on the service provider link to find information about their respective services and privacy practices.

4. SDK & TRACKING TECHNOLOGIES

Our Services and some of our Service Providers utilize “cookies” or “software development kits (“SDK”)” anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps and Services as a whole.

AccDataotection and privacy laws may grant you certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and, and) withdraw consent (to the extent applicable). If you wish to submit a request to exercise your rights, please fill out the Data Subject Request Form (“DSR”) available.

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you to fortify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

6. DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all by applicable laws, or until an individual expresses a preference to opt out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, with or without previous notice to you.

7. SECURITY

We take great care in implementing physical, technical, and administrative security measures for the services that we believe comply with applicable regulations and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.

8. DATA TRANSFER

We use Google Cloud which is located in the EU, US, and Asia.  Further, certain processing activities are conducted in Israel, or other countries. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.

9. CHILDREN

Our App and Services are intended for a general audience and are not directed to persons under 13 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 13 years old. If we become aware that a person under 13 years old has provided us with Personal Data, we will delete such data from our databases.

11. CHANGES AND UPDATES

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. I  we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification concerning such changes if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Amended” heading located at the top of this Privacy Policy.

12. CONTACT US

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us.