Comi Chat Privacy Policy

Effective date: 20/11/2025

1. INTRODUCTION

The Comi Chat mobile application ("the Service") and its official website https://www.hi-ruby.cc are operated by the Comi team under the leadership of app developer yame team (herein referred to as "we," "our," or "us"). This Privacy Policy (the"Policy") is an integral part of the Comi Chat Terms of Services (the"Agreement"). All the terms used herein are used with the same meanings as the Agreement provides unless otherwise are directly set out hereby.

We are committed to protecting and respecting your privacy, so we take your privacy seriously and will use your personal data (the"data") to administer your account and to provide the services only after obtaining your consent for the collection and processing of your data as follows. The Policy explains what data, when, where, and why we collect the data of yours, on what legal basis we process and how do we use it, the conditions under which we may disclose the data to others, your rights in respect of your personal information, as well as how we keep it secure. Whether you have any questions, please contact us via [email protected]

By using the Service, you agree that collection and processing of your data will be covered by terms of this Policy.

2. INFORMATION WE COLLECT

To provide and enhance our Service, we collect several types of information:

2.1. Account Information: During registration, we collect data necessary to create your profile. This includes your username, email address, date of birth, gender, profile pictures, and location. You may also link third-party accounts (e.g., Google), in which case we receive relevant login information.

2.2. Profile Content: The information you choose to share on your profile is public. We strongly advise against sharing sensitive personal details such as your full legal name, address, phone number, financial information, or national ID numbers.

2.3. Payment Data: For purchases made within the Service, we process your payment details securely. This information is retained for fraud prevention, audit, and tax compliance purposes. Our systems employ automated decision-making to block transactions that exhibit characteristics of fraud.

2.4. Device Data: We automatically collect information about the device you use to access the Service, including its unique identifier, model, and operating system, for purposes such as functionality optimization and security.

2.5. Communications: When you contact our Customer Support team, we receive your email address and the content of your message. We may also collect your IP address. Records of these communications are retained for up to 5 years after account deletion.

2.6. Cookies and Tracking Technologies: We use cookies and similar technologies on our website and app to recognize your device and remember your preferences.

3. THE WAY WE USE YOUR PERSONAL INFORMATION

We process your personal data for the following purposes:

- To create, manage, and maintain your account.

- To deliver the core functionalities of the Service, including profile management, user-to-user communication, and processing payments for premium features.

- To manage our relationship with you, which includes notifying you of changes to our terms or policies.

- To ensure the security and integrity of our Service, including fraud prevention, troubleshooting, and system maintenance.

- To utilize data analytics to improve our Services, marketing strategies, and user experience.

- To comply with legal obligations and respond to legitimate requests from law enforcement and other authorities.

4. DEVICE PERMISSIONS

To enable full functionality, the app requests certain device permissions:

- Camera: Used for capturing photos and videos within the app for your profile, posts, and video calls.

- Microphone: Necessary for transmitting audio during video calls.

- Storage (Read): Allows the app to access media files from your device's storage for uploading and sharing within the app.

- Storage (Write): Enables the app to save media files (e.g., photos, videos) to your device's gallery.

5. STORING AND REMOVING PERSONAL DATA

5.1 Personal information, which we process for any purpose, will not be stored for a longer time than is required for this purpose.

5.2 Users can request the removal of their account via our Service.

If you want to delete your account, log into your account and navigate to the account settings - click "Account deletion" - complete the deletion request. After the processing period, your account and associated personal data will be permanently deleted, and reactivation will not be possible.

5.3 We will store and remove your personal information for the users who have removed their account:

- We will delete your confirming identity analytics data following 30 days period after account deletion.

- We will hide your public profile after 30 days since you delete your account.

- We will remove your communication after 30 days after the deletion of your account. The screenshots taken randomly by our system for tracking and preventing unlawful and abominable user behavior are being overwritten all the time and are held for 90 days.

- We will remove your login details, account and ID data, technical, and trade data 90 days after the deletion of your account.

5.4 In certain instances, we are not able to specify beforehand the time periods during which your personal information will be kept. In such instances, the period of retention is determined according to the time period during which having access to the data is essential to us for providing services, getting payment, addressing customer support matters, other issues, or in the event of other legal or auditing reasons.

5.5 In spite of other provisions hereof, we might hold your personal information for a rational time period, and when such storing is needed to meet a legal foundation, we are subject to, for protecting your fundamental interests or the fundamental interests of another physical person.

6. DATA SHARING AND DISCLOSURE

We do not sell or rent your personal data to third parties. However, we may share your information in the following limited circumstances:

- With your explicit consent.

- With trusted third-party service providers who assist us in operating our Service (e.g., payment processors, analytics providers), under strict confidentiality agreements. This includes the use of "Adjust Analytics" (Adjust GmbH, Germany) for analyzing app usage, which may involve your IP address.

- With our professional advisors (e.g., lawyers, auditors) where necessary for obtaining advice or managing legal disputes.

- When required by law, regulation, or legal process, or in connection with a merger, acquisition, or sale of assets.

7. DATA RETENTION

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, including to meet legal, accounting, or reporting requirements. When determining retention periods, we consider the nature of the data and the purposes for processing. Data may be anonymized for long-term statistical use. Indefinite retention is applied to blacklists of fraudulent activities to protect our Service and users.

8. YOUR RIGHTS

8.1 Here we summarize the basic rights you have pursuant to data protection law. Several rights happen to be complex and can include limitations based on the warrants of law for information processing, and several details are not included in the summary. Respectively, you are advised to read the corresponding directories and laws from the oversight bodies to find a complete explanation of such rights.

8.2 Below are your basic rights according to data protection law:

- Access right. You are entitled to confirm, whether we can process your personal information or not, and, if we do, access to your personal information. If such an act doesn’t prejudice the rights and freedoms of other people, we will be able to deliver you a copy of your data. The first copy is provided for free, whereas extra copies maybe for a fee. To access your personal data, you can get in touch with our Customer Support.

- Right to rectification. You can request to correct any misinformation about you and, considering the aim of processing, to complete any partial personal information about you.

- Right to erasure. You can request to erase your personal information. Our policy for keeping and removing personal data is described in the 5th paragraph above.

- Right to answer back the processing. You are entitled to answer back to your information processing by our Service for reasons of your peculiar situation, but only when there is a lawful excuse for processing like this, that it is required for conducting a task, which is done for the public benefit or under the procedure outlined by any official body assigned to us; or the purposes of the lawful rights which we or any 3rdparty pursue. In case such objection is made, we terminate the processing of your data if no reasonable, lawful excuse for this processing is provided by us to outweigh your interests or rights and freedoms; otherwise, such processing is for the government circles, exercise, or protection of lawful claims.

- The right to limitation. You are entitled to ask for the termination of your data processing in peculiar cases, for example, when your right to object is exercised as specified above, or when you fight for accuracy of your information, that is processed by us.

- Data portability right. To the effect that your consent is the legal background for us to process your information, and we conduct such processing with the help of automated means, you may request us to supply you with your information in a structured way, which is in a generally valid and machine recognizable format. This right is not applied, though, in cases, when may prejudice rights and freedoms of others.

- Right to complain to an oversight body. If you think that the information about you, which we process, breaches data protection laws, you are entitled to complain to an oversight body liable for data protection. Your complaint may be lodged in the EU member state of your permanent residency, workplace, or the place of the suspected offense.

- Withdraw consent right. To the effect that the legal background for your personal information processing the consent, you are entitled to withdraw your consent anytime. Such withdrawal shall not affect the legitimacy of processing prior to the withdrawal.

8.3 Without prejudice to the abovementioned, in case of justified doubts regarding the user identity, who exercises his/her rights described in the 8th paragraph, or if we consider it necessary because of security reasons, we might request such a user to provide extra information, and be it further, take all rational measures required to prove the user identity. You can enforce your rights in connection with your personal information by means of contacting Customer Support.

9. CHILDREN'S PRIVACY

Our Service is strictly for users aged 18 and over. We do not knowingly collect information from anyone under 18. If we become aware of such a case, we will take immediate steps to delete the data from our servers.

Although the Application herein is not for the use by people younger than 18, we understand that children can make an effort to access it. Personal information is collected from the children younger than 18 unintentionally, and we take every measure to prevent such access to the Application herein by people of the age limit mentioned above. In case you are a guardian or a parent and think that your child may be using the Application herein, please, contact us. Prior to deleting any data, we can request a proof of identity to avid the felonious deletion of the account details. In case we find out that children use our Application, their information will be removed with reasonable expediency.

10. DATA SECURITY

We implement robust technical and organizational measures, including firewalls and data encryption, to protect your personal data against unauthorized access, alteration, or destruction. However, no internet-based service can be 100% secure. You can help maintain security by using a strong password, logging out after each session, and not sharing your login credentials.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. The "Effective date" at the top will reflect any changes. We will notify you of significant updates through the Service.

12. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

- Via email: [email protected]

- Through the in-app customer service feature

- Through official website: https://www.hi-ruby.cc