If you live in the European Union, the company that is responsible for your information under this Privacy Policy (the “data controller”) is:

Mobile Investment GmbH
c/o WeWork
Pilgrimstr. 6
50674 Cologne
Germany

This Privacy Policy applies to websites and mobile applications operated by Chaty. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

We collect information generated as you use our services, for example access logs, as well as information from third parties. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

• When you create an account, you provide us with at least some additional basic details necessary for the services to work, such as your location. You may also provide us with photos and a personal description.

• When you use the services you give us permission to collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including IP address, GPS, Bluetooth or Wi-Fi connections.

• When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.

• When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.

• If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.

• If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.

• We also process the content you publish, as part of the operation of the services.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

• Other Users

  Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

• Other Partners

  We may receive information about you from our partners, for instance where Chaty ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

Information collected when you use our services

When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

• Usage Information

  We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring web page address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges).

• Device information

  We collect information from and about the device(s) you use to access our services, including:
  

• hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);

• your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including IP address, GPS, Bluetooth or Wi-Fi connections.

• information on your wireless and mobile network connection, like your service provider and signal strength;

• information on device sensors such as accelerometers, gyroscopes and compasses.

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Chaty, do not currently respond to DNT signals.

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide our services to you

• Create and manage your account

• Provide you with customer support and respond to your requests

• Complete your transactions

• Communicate with you about our services, including order management and billing

To help you connect with other users

• Analyze your profile and that of other users to recommend meaningful connections

• Show users’ profiles to one another

To ensure a consistent experience across your devices

• Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

To provide new Chaty services to you

• Register you and display your profile on new Chaty features and apps

• Administer your account on these new features and apps

To serve you relevant offers and ads

• Administer sweepstakes, contests, discounts or other offers

• Develop, display and track content and advertising tailored to your interests on our services and other sites

• Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

To improve our services and develop new ones

• Administer focus groups and surveys

• Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)

• Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To prevent, detect and fight fraud or other illegal or unauthorized activities

• Address ongoing or alleged misbehavior on and off-platform

• Perform data analysis to better understand and design countermeasures against these activities

• Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

• Comply with legal requirements

• Assist law enforcement

• Enforce or exercise our rights, for example our Terms

To process your information as described above, we rely on the following legal bases:

• Provide our services to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our services to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.

• Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

• Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

• With other users

  When you create an account, your Chaty profile will be viewable by other users of the services. Other users will be able to view information you have provided to us, such as the photos you upload, your name, your age, approximate number of miles away, your personal description, and information you have in common with the person viewing your profile.
  Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.
  

• With our service providers and partners

  We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
  
  We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
  
  We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
  

• For corporate transactions

  We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

• When required by law

  We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
  

• With your consent or at your request

  We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
  
  We may use and share non-personal information (meaning information that, by itself, does not identify who you are, such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.
  

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data

We want you to be in control of your information, so we have provided you with the following tools:

• Access tools in the services. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the services. If you have any questions on those tools and settings, please contact us at [email protected].

• Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

• Deletion. You can delete your account by using the corresponding functionality directly in the settings of the services.

We want you to be aware of your privacy rights. Here are a few key points to remember:

• Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information directly in the settings of the services.

• Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at [email protected].

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our services to you anymore.

• Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

• Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law.

In practice, we delete or anonymize your information upon deletion of your account unless:

1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the services.

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

If you have questions about this Privacy Policy, here’s how you can reach us:

Email: [email protected]

By post:
Mobile Investment GmbH
Privacy Officer
c/o WeWork
Pilgrimstr. 6
50674 Cologne
Germany