1. Introduction
1.1. This Privacy Policy (hereinafter referred to as “Policy”) applies to our video-chat application, ChitCam (hereinafter referred to as “Service”). The term “Service” also refers to our website, https://ChitCam.com/. (All product names, logos, and brands used on our websites are properties of their respective owners.)
1.2. We are committed to safeguarding the privacy of our data subjects (“you” or “User”). In this Policy, we explain how your data, meaning any information relating to you as an identified or identifiable natural person, that we may hold about you, is collected, used, stored, disclosed, and removed (each and all referred to as “processing”).
For more information, please read Section 2 of this Policy.
1.3. This Policy only applies to the information we process. It does not apply to the practices of companies that we don’t own or control or employees that we don’t manage. Information available via our Service may contain links to third-party applications or websites, and any information you provide to those sites will be covered by any privacy policies they may have.
Please be sure to read the privacy policies of any third-party applications and/or sites you visit. It is those sites’ responsibility to protect any information you give them, so we can’t be held liable for their wrongful use of your personally identifying information.
1.4. We may update this Policy from time to time and will notify you of changes to the Policy affecting your rights by email and/or by posting on our website at https://chitcam.com/privacy-policy.
2. Your Data and How We Use It
In this Section 2, we set out:
(a) the general categories of data and types of personal data that we may process; (b) the source of that personal data; (c) the purposes for which we may process personal data; and (d) the legal bases of the processing.
2.1. We may process your registration data.
Registration data may include your full name, photo (your “avatar”), ID, username and email address, gender, date of birth, country, region, and city of residence as well as your social network account data. The source of the data is you. Registration data is required for you to be able to access and use the Service. The legal bases for this processing are consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.2. We may process your PC or software data.
All the personal data that is automatically sent by the User’s installed software, including the User’s IP address, cookies files content, personal data sent by the browser or another software that allows you to access our Service, as well as date/time and your requested page URL, E-wallet ID, CSP name and exact date/time of the SMS-message sent and its content. If you buy products or services from us, we may collect your first and last name, partial credit card number, and/or other payment information. The legal bases for this processing are consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We use our commercially reasonable efforts to make sure your credit card number and other payment information are kept strictly confidential by using only third-party billing services that are GDPR compliant and use industry-standard encryption technology to protect your credit card number from unauthorized use.
2.3. We may process your usage data.
Usage data is data about your use of the Service. Usage data is primarily non-personally-identifying information of the sort that web browsers, servers, and services like Google Analytics typically make available, such as the browser type, language preference, referring site, and the time of each visit. Other information that we might have access to includes how you use the Service (e.g., search queries), your approximate location, etc.
Usage data may include:
- Data that we collect mainly for behavior statistics, business intelligence, and email campaigns (“analytics data”). We gather the Service traffic data with the help of Google Analytics.
- Data that we collect mainly for technical, security, and/or fraud prevention reasons or for tracking errors (“technical data”).
The legal basis for this processing is our legitimate interests and/or those of third parties, namely to monitor the quality of the Service and improve the Service as well as to prevent, detect, and investigate fraud, criminal activity, or other misuse of the Service, and to prevent security issues.
2.4. We may process your communication data.
Communication data is information contained in or relating to any communication that you send to us or generate through the use of our Service.
Communication data includes:
- All your messages, requests, and other communication with our Customer Support, which may happen during the dispute review process or via support tickets, emails, or using any other communication tool; and
- All your communications and file attachments or other data that you generate mainly by communicating with other Users.
Communication data may include email address, username, avatar, IP address, full name, audio, and video files, and in the case of manual ID verification: a photo of the User’s ID, a photo of the User, and a photo of the User’s utility bill or related document. Our system may also randomly take screenshots of your communications with other Users. The communication data may be processed to communicate with you, record-keeping, review, and resolve disputes, prevent illegal and objectionable behavior, serve our customers better, and improve our Service. The legal bases for this processing are our legitimate interests, namely the proper administration of our Service and business, and the prevention of illegal and/or immoral behavior.
2.5. We may process your notification data.
Notification data is information that you provide to us to subscribe to our email notifications, SMS notifications, and/or newsletters. The notification data may include your email address, phone number, username, and full name. The notification data may be processed to send you the relevant notifications and/or newsletters. The legal basis for this processing is consent. You can unsubscribe at any point by contacting us, unchecking a box in your Profile Settings, or clicking the unsubscribe link in the email.
2.6. We may process any of your data when necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or outside the court procedure.
This may include using information for legal compliance, litigation or pre-litigation, security monitoring, and investigation. You agree that your data may also be used as evidence that the Service was used by you in case a dispute arises between us and the User. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, our legal rights, and the legal rights of others.
In addition to the specific purposes for which we may process your data set out in Section 2, we may also process any of your data where such processing is necessary to protect your vital interests or the vital interests of another natural person.
The company does not determine the validity of the personal data provided by you; we assume that you provide accurate personal data and keep it updated. Please try to avoid supplying any unnecessary personal data to us.
3. Information You Choose to Display Publicly via Our Service
3.1. Some Users may elect to publicly post personally identifying or sensitive information about themselves in their normal use of our Service. This could occur through the use of optional profile fields, interactions in chats, or if a previously private interaction is made public. Information like that, which is voluntarily posted in publicly visible parts of our Service, is considered to be public, even if it would otherwise be considered personally identifying or sensitive. Voluntarily publicizing such information means that you lose any privacy rights you might normally have about that information.
3.2. Please also remember that if you choose to provide personally identifiable information using certain public features of our Service, individuals reading such information may use or disclose it to other individuals or entities without our control and your knowledge, and search engines may index that information. We, therefore, urge you to think carefully about including any specific information you may deem private in the content that you create or information that you submit through our Service.
4. Providing Your Data to Others
Third-Party Access to Your Data
We may grant access to your data to third parties under certain circumstances:
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Explicit Consent: If you give your explicit consent, we may share your data with third parties.
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Service Requirement: If sharing your data is necessary for you to use the Service, we may share it with third parties. In these cases, we ensure the confidentiality of your data.
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Processing Payments: For processing payments, we use services provided by the following entity:
- Comewell Limited – located in the UK. The Registered Office of the Company is situated at Office 237b, 1st Floor Norwich House, Savile Street, Hull, HU1 3ES, UK
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Behavior Statistics and Email Campaigns: For behavior statistics, business intelligence, and email campaigns, we use services provided by Google Analytics, a company located in the United States. Data we provide to Google Analytics may include your IP address and is used to generate information about your usage of our Service.
Additional Disclosures of Personal Data
We may also disclose your data under the following conditions:
- Professional Advisors: To our auditors, lawyers, accountants, consultants, and other professional advisors, if necessary, for obtaining professional advice or managing legal disputes and risks.
- Legal Compliance: Where necessary for compliance with a legal obligation or to protect your vital interests or those of another person.
- Merger or Acquisition: As necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets, with notice to users.
Links from Other Websites
Other websites may contain links to our Service. We ensure they are not involved in illegal activities and are GDPR compliant. However, these websites are not under our control and are not subject to this Privacy Policy. They will likely have their privacy policies and terms of use. We have no responsibility for these websites. Your use of and access to these websites are solely at your risk. It is your responsibility to check their privacy policies.
Protecting Children’s Privacy
Our Service is not designed for use by anyone under 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe your child is using our Service, please contact us. We will delete their information within a reasonable period if we discover that a child is using our Service.
Unlawful Activity
We may investigate complaints or reported violations and take any action we deem appropriate. This includes reporting any suspected unlawful activity to law enforcement officials, regulators, or other third parties and disclosing any necessary information to such persons or entities.
International Transfers of Your Data
We store your information primarily within the European Economic Area. However, some features and requirements of the service involve transferring your information to third-party service providers outside the European Economic Area. These transfers will be covered by the standard data protection clauses adopted by the European Commission or by another appropriate safeguard mechanism such as the Privacy Shield Framework.
Retaining and Deleting Personal Data
We retain your data only as long as necessary for the purposes set out in this Policy.
- Account Deletion: You may request the deletion of your account through our Service.
- Retention Periods:
- Personally identifiable analytics data is removed 30 days after account deletion.
- Your public profile will be hidden 30 days after you delete your account.
- Communication data will be deleted 5 years after account deletion.
- Registration data, account data, ID data, trade data, and technical data will be deleted 5 years after account deletion.
In some cases, it may not be possible to specify retention periods in advance. We determine the period of retention based on the period we need to access the data for the provision of services, receiving payment, resolving customer support issues, or other auditing or legal reasons.
Your Rights
You have several rights under data protection law, including:
- Right to Access: You can request confirmation of whether we process your data and, where we do, access to the personal data.
- Right to Rectification: You can request that we correct any inaccurate personal data about you.
- Right to Erasure: You can request that we delete your data.
- Right to Object to Processing: You can object to our processing of your data on grounds relating to your particular situation.
- Right to Restriction: You can request that we restrict the processing of your data in certain cases.
- Right to Data Portability: You can request that we transfer your data to another service provider.
- Right to Complain: You can complain to a supervisory authority if you believe our processing of your data infringes data protection laws.
- Right to Withdraw Consent: You can withdraw your consent to our processing of your data at any time.
Cookie Policy
We use cookies to improve your experience and enable certain features of our Service.
- What are Cookies?: Cookies are tiny files saved to your web browser.
- Cookies We Use: We use cookies to manage the signup process, prevent abuse and misuse of our Service, remember when you are logged in, and set your preferences.
- Cookies Used by Service Providers: We use Google Analytics to analyze the use of our Service.
- Managing Cookies: You can prevent the setting of cookies by adjusting your browser settings. However, disabling cookies may downgrade or break certain elements of the Service’s functionality.
This Policy may be updated from time to time. We will notify you of changes to the Policy affecting your rights by email and/or by posting on our website.
Contact Us
If you have any questions about this Privacy Policy, please contact our Customer Support.