| English |
PRIVACY POLICY
Last updated: 01.04.2025
PLEASE READ THESE TERMS CAREFULLY ALONG WITH OUR TERMS OF USE, WHICH ARE REFERENCED HEREIN . BY USING APPS AND SERVICES LISTED BELOW, YOU ACKNOWLEDGE THAT YOU HAVE REVIEWED THESE TERMS OF SERVICE AND AGREE TO BE BOUND BY THEM
1. General information
1.1. References in this Terms of Use to “ Service ”, “ App ” refers to application “ChatEver” and other related services (including respective application website) operated by RED PANDA APP LLC, a limited liability company registered in the USA under the company number 202211291642638, having its address at 11510 Old Oakland Blvd N Dr, Indianapolis, IN, 46236.
1.2. The Company is the data controller of the Personal Data processed within the framework of present Privacy Policy related to Services hereto. The Company is committed to protecting and respecting the privacy of its Users and ensures their security when using the Service. This Privacy Policy is intended to help the Client to understand what data and for which purposes the Company collects, how collected data is processed and protected.
1.3. By using the Services, you affirm that you are at least 18 years old or have reached the age of majority in your jurisdiction, or that you have reviewed these Privacy Policy with your parent or guardian who agrees to these Privacy on your behalf.
Individuals under 18 years old are prohibited from using our App or Services, as they are not intended for that age group. We will delete any personal data we believe to be from users aged 18 or younger. If you suspect that we have collected personal data from someone under 18 (or the age of majority in your jurisdiction) or aware that a child or minor has provided personal information on the App or within the Services, please reach out to us at [email protected] , so we can take appropriate action.
By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Use.
The Company may and will terminate any Client’s account upon discovery that respective account was created with violation of the provisions of this paragraph.
1.4. You may be required to register for an account (" Account ") to use certain Services or access them through a social networking service (" SNS "). Your Account is personal, and you may not transfer, lease, or sell it to anyone. You agree to provide accurate and up-to-date information when registering and are solely responsible for maintaining the confidentiality of your login details.
By registering with the Service, the Client consents to the processing of his/her Personal Data by the Service in accordance with the provisions set below.
By registering with the Service, the Client gives consent to the Company to anonymize his/her Personal Data for the purposes of further use in anonymized form in order to improve the performance of the Service.
1.5. The Company reserves the right to amend this Privacy Policy; therefore, it is recommended that the Client of the Service checks Privacy Policy on a regular basis. The service will send a notice or an email regarding such changes to the Client.
1.6. All the changes to this Privacy Policy are effective as of the “Last updated” date. We may notify you about changes to this Privacy Policy by placing a notice via the Services, this website or App. The Client who continues to use the Service after the Last updated date it deemed to accept the changes made to it. We encourage you to periodically check back and review this Policy so that you always know our current privacy practices.
2. Contact information
2.1. The Company has designated a Data Protection Officer (“ DPO” ) who could be reached by emailing at [email protected] . For any questions about this Privacy Policy, please email your questions via email provided hereto or use the support methods available in our Services.
3. Collection of data
3.1. When using the Services, the Client agrees to the processing of the following Personal Data:
3.1.1. Personal Data that the Client provides to the Service:
a. When creating an account, the Client provides the Service with at least his/her login credentials (including unique username and password combination for the Client’s account), as well as basic details necessary for the Service to work, such as the Client’s name, gender and age.
b. When completing his/her profile, the Client could provide additional information, such as details on his/her physical characteristics (including height, weight, body type and sexual preferences), background (including education, financial situation, housing situation and ownership of a vehicle), personality (including purpose of acquaintance, sociability and attitude towards children), lifestyle (including attitude towards alcohol and smoking), date of birth, interests and other details about the Client, as well as content, such as pictures and photos.
To add certain content, such as pictures and photos, the Client may be required to provide expressed approve to allow the Service to access his/her camera or device’s photo album. We understand the importance of protecting your privacy and want to provide transparency regarding the collection and usage of face data. Please see the "Face Data" section for more information on how we may use face data.
Some of the information provided by the Client may be referred to as belonging to Special categories of Personal Data, pursuant to legislation of certain jurisdictions, such as the Client’s racial or ethnic origin, sexual orientation, political opinions or religious or philosophical beliefs. By placing such information in Client’s account, the Client consents to the processing of the information by the Service.
c. When contacting Support Service, available through a separate chat in the App: the information that the Client provides during the interaction. The Company reserves the right to monitor or record interactions between the Client and the Support Service for training purposes and to ensure high quality of service.
d. When participation in Client verification procedures: Client’s Personal Data, as requested by the Service for the Client identification purposes.
e. When participating in surveys or focus groups: insights and evaluation of the Company’s services, responses to the questions from the Service.
f. When communicating with other Clients through a chat in the App: the contents of the relevant chat (including cases when such contents include Personal Data);
3.1.2. Personal Data collected through the use of the Service:
When the Client is using the Company’s App, the Service may collect data regarding the device(s) the Client uses to access the Service (such as his/her IP address, device identifier (including unique advertising device identifiers, for example Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data (upon a separate consent from the Client).
3.1.3. Personal Data collected from third parties:
The Client can connect Client’s account to a social network (including but not limited to Facebook) by way of registering through the corresponding social network. After connecting his/her account in a social network, the Client would be able to add the personal information from his/her profile in corresponding social network to his/her profile in the Service. The following information could be received by the Client from the social network: the Client’s name, ID within the respective social network, photo, email address, IP address, phone number, age, gender, preferred language, country, information about the Client’s device, location, list of friends in the social network, data on the use of other networks (as contained in the respective social network). By connecting his/her Client’s account with the Company to a social network, the Client gives an explicit consent to the processing of the Client’s Personal Data contained in his/her account in the respective social network.
3.2. By providing Personal Data to the Company, the Client warrants that such data is true, accurate and up to date.
3.3. For collecting the above-mentioned data we may use the following software and programs:
| Name | Registered Seat | ||
| Facebook Ads (Meta Platforms, Inc., Meta Platforms Ireland Limited) | 1601 Willow Road, Menlo Park, CA 94025, USA Merrion Road, Dublin 4, D04 X2K5, Ireland |
4. Use of User’s/Client’s personal data
4.1. The Company collects, process and uses Personal Data of Clients of the Service based on the following grounds:
a. when such processing is performed in order to fulfil the contract between the Service and the Client;
b. based on legitimate interest of the Service;
c. upon explicit prior consent from the Client.
4.2. The Company collects and processes Personal Data of the Service’s Clients in order to maintain, improve the functionality of the Service and to ensure compliance with legal and business-related requirements.
The User’s/Client’s Personal Data is processed for the following purposes:
4.2.1. When processing of personal data is related to fulfilment of the contract between the Service and the Client:
a. to set up, operate and manage the Client’s account and, if necessary, to contact the respective Client through the means provided by the Client upon registration, in connection with the operation and management of the Client’s account;
b. to analyze the Client’s profile, activity on the Service, preferences and current location in order to recommend the Client’s profile to the other Client’s of the Service and to recommend the other Clients’ profiles to the Client;
c. to proceed and respond to the requests and enquiries received from the Client;
d. for administrative purposes, such as password reminders, service messages (including but not limited to the App’s maintenance messages, updates to the Service’s Privacy Policy and Terms of Use);
4.3.2. Under legitimate interests of the Service:
a. to connect the Client’s account to a social network (including but not limited to Facebook);
b. for Client verification purposes, conducted in relation to an ongoing or alleged misbehavior, performed by the Client of the Service, in order to block accounts as part of the Services anti-spam procedures, to investigate possible fraud;
c. to evaluate the effectiveness of marketing and to perform market research and training.
4.3.3. Under an explicit consent from the Client:
a. to facilitate networking opportunities of the Client with the Service by way of allowing him/her to add additional information to the Client’s account (including information on the Client’s sexual orientation);
b. to process Personal Data from the Client’s account in a third-party social network, connected to the Client’s account with the Company;
c. to serve the Client with targeted in-App advertisements;
d. for remarketing purposes, allowing the Service to identify the Client who has previously visited the App and optimize advertising information according to the Client’s preferences. This feature is used by the Service through third-party services such as Google Advertising, myTarget and Facebook;
e. to prepare statistics regarding the use of the Services by the Client;
f. to identify possible technical malfunctions in the work of the Service, to assist internal research and development and to make improvements to the App or Services.
4.4. Face Data
4.4.1. When using our Apps and Services, we may collect your images to provide appropriate services, but this information is not used for identification.
4.4.2. Our Services do not employ facial recognition, biometric templates, or any regulated systems. We strictly comply with applicable laws, ensuring that no activities involving facial information ("Face Data") or the creation of biometric templates occur, thereby prioritizing user privacy.
4.4.3. We may collect photographs via your camera or camera roll, which may include Face Data. However, we do not access your photo albums, even if permission is granted. While photographs are not classified as biometric identifiers, we recognize that they require a high level of protection equivalent to other sensitive information.
In compliance with the law, we ensure that:
4.4.3.1. Face Data is used solely for specific features within the App. We may store Face Data for technical purposes without automated processing for identification. We do not extract or store face geometry or biometric identifiers.
4.4.3.2. Consent and User Control: We obtain your explicit consent before collecting any personal data, including photographs with Face Data. You retain control over the face data shared with our App, and we will seek additional consent for any other intended use.
4.4.3.3. Storage and Security: We securely store photographs containing Face Data on our servers or locally on your device, implementing technical and organizational measures to protect against unauthorized access. Photographs will be retained only as long as necessary to fulfill their intended purpose. Upon completion of the purpose or withdrawal of consent, we will securely delete your data.
4.4.3.4. Third-Party Access and Data Sharing: We do not share or disclose your photographs containing Face Data to third parties unless explicitly stated and with your prior consent.
4.4.3.5. Data Retention: You have the right to request deletion of your photographs containing Face Data at any time. For more information, please see Section 5 on Data Retention.
4.4.3.6. Please note that we do not use your photographs for any purpose other than those mentioned above.
4.4.4. We do not sell, lease, trade, or profit from your biometric identifiers or information.
4.4.5. If you have questions or concerns about our practices, please contact us at [email protected] .
5. Duration of the Сlient’s data retention
5.1. The Company retains your Personal Data only as long as necessary for the purposes outlined in this policy or and as permitted by applicable law in order to carry out relevant actions or provide relevant Services. We may retain Personal Data for a shorter period unless it is required for security enhancements or functional improvements.
Personal Data, that the Client has communicated to the Service upon registration and subsequently using the Service, will be retained by the Service as long as the Client remains the Client of the Service.
5.2. To protect the safety and security of the Clients of the Service, the Company implements a safety retention window of 30 days following a Client’s account termination.
5.3. The Company reserves the right to store the Client’s Personal Data for a longer period of time than provided in paragraph 5.1., when it is performed in order to fulfill the legal obligations of the Service (including law enforcement requests, dispute resolution), ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of the Service’s legitimate interests (including security reasons, prevention of fraud).
6. Disclosure of Personal Data
6.1. The Company may disclose your Personal Data in good faith if required by law, to protect our rights, or in response to legal requests from public authorities. This includes compliance with legal obligations, protection of our rights, and addressing legal liabilities.
6.2. The Company may disclose the Client’s Personal Data with third parties in the following cases:
a. Other Clients of the Company :
The Client shares information with other Clients of the Company by way of voluntarily disclosing information on the Service (including but not limited to information in Client’s profile).
It is in the Client’s discretion to choose the information to be disclosed with the Service and the Company rescinds from responsibility for the other Clients of the Service regarding the way they might use such information, disclosed by the Client.
b. Third-party advertising services (Data Processors or Service Providers). The Company uses the following services (list is provided alongside with privacy policies of the relevant services):
c. Third-party analytics services . The Company uses the following services (list of services is provided alongside with privacy policies of the relevant services):
d. Cloud services providers :
e. Client support services . All requests of Clients of the Company are processed by a third-party Client support service UseDesk (privacy policy available at https://usedesk.com/privacy )
f. Partners. The Company may engage its partner APPLICAVE LLC, a company incorporated in the USA under Business ID 202003171380935 with its principal place of business at 9165 Otis Ave, Suite 238, Indianapolis, IN 46216, USA, to facilitate payment processing in certain jurisdictions. In scope of this engagement, APPLICAVE LLC may collect and process Client’s data and in this case it will act as a Data Processor.
g. Providing Client’s data by law:
The Company may disclose Client’s Personal Data when such disclosure is required by law and is reasonably necessary:
6.2. The Company ensures appropriate contractual control over third parties assisting the Service in processing the Client’s Personal Data, securing that rights of Clients of the Service are upheld, their Personal Data is secure, appropriate security and privacy arrangements are in place.
6.3. In the event of change in the corporate structure of the Service, resulting in transfer of the Client’s Personal Data to a third party, all the Clients of the Service would be notified of such changes via email and through a notice posted on the Service’s website. Respective notice would explain the identity of the new data controller and the Client’s options regarding disposal of their Personal Data.
7. Client’s Data Protection Rights
7.1. Every Client of the Service is a data subject and thus has ultimate rights over his/her Personal Data.
7.2. The rights of data subject over his/her Personal Data are as follows:
Access - A right to know whether Personal Data concerning the Client is being processed by the Service, right to get information regarding processing of Personal data, right to request a copy of Personal Data being processed.
Erasure - A right to request ‘to be forgotten’, meaning deletion of the Client’s Personal Data from the database of the Service so that the Service is not able to continue processing and storing of such data, with exceptions, provided by applicable law.
If you wish to delete personal data collected during your use of our Services, please send a request to [email protected] . Processing may take some time. Note that changes or deletions apply only to future activities and communications, and previously shared data with third parties (e.g., other users or credit card companies) may still be retained for lawful purposes. We may retain data as required by law or legitimate interests. Additionally, your email will be stored to prevent duplicate accounts. Cached content beyond our control may persist online after deletion.
Rectification - Right to ask the Service to correct Client’s Personal Data in a situation when such data available to the Service or disclosed to third parties is inaccurate or incomplete.
Object - Right to object to processing his/her Personal Data in a case when the corresponding processing is not performed on the basis of the Client’s consent.
Restrict processing - Right to introduce the restriction regime on the processing of the Client’s Personal Data, so that in each case the data may be processed only upon separate consent from the Client.
Data portability - Right to request for the Personal Data provided to the Service to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by the Client.
Withdraw consent - Right to withdraw consent to processing of his/her Personal Data by the Company and/or third-party processors of Personal Data. The Client should note that withdrawal of consent to the processing of his/her will result in the deletion of his/her profile with the Service and the termination of his/her use of the Service.
Lodge a complaint - Right to lodge a complaint to your supervisory authority
7.3. The abovementioned rights are not absolute. In order to exercise some of the rights, the Client should meet certain conditions and requirements, specified by the law.
7.4. For more information regarding Cliens’s rights over Personal Data, the Client of the Service should contact [email protected] . In order to exercise his/her rights, the Client should submit a request to [email protected] .
7.5. The Client of the Service should also be acknowledged of his/her right to complain to a data protection regulator in his/her jurisdiction.
8. Protection measures
8.1. When using the App, Client’s personal data is transferred by the Service as follows:
a. to the domain the Company.me, which belongs to the Company;
b. to the Amazon Cloud Services server (more information could be found on this link: https://aws.amazon.com/ ).
8.2. The Company works hard to protect its Clients from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as any other technology companies, although the Company takes steps to secure Clients’ information, it could not be promised or guaranteed, that unauthorised access, hacking, data loss, or other breaches will never occur.
The Company reserves the right to suspend the Client’s account without notice if there is a reasonable suspicion of breach of security or unauthorised access to such account. If you believe that your account or information is no longer secure, please notify the Company immediately by sending a message at [email protected] .
8.3. The Client should take reasonable steps in order to keep his/her Personal Data (including the account’s password) safe. It is recommended that the Client does not share account’s password with anyone.
9. Cookies
9.1. In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, the Company uses cookies and similar technologies in order to track the interaction of Clients with the App. This section explains the different types of cookies that may be set when the Client uses the App, helping to understand and manage them as he/she wishes.
9.2. A cookie is a small file that is stored locally at the Client’s technical device as soon as the App is being visited. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection. Should the Client open the App again later, a cookie will transmit this data back to the App. The App’s cookies don't store personal information like the Client’s name or address.
9.3. Types of Cookies
the Company’s App uses different types of cookies:
9.4. The Client can at any time reset device identifiers by activating the appropriate setting on his/her mobile device. The procedure for managing device identifiers is slightly different for each device.
9.5. Below is information about how the Company uses Clients’ cookies in the App:
Necessary cookies - These cookies are strictly necessary to provide the Client the Company’s services.
Authentication cookies - These persistent cookies help the Service to identify the Clients so that the Client could log into the App automatically.
Analytics cookies - These cookies help the Service to understand how the App is being used, and help us customize and improve the Service.
List of relevant providers:
Google analytics - https://marketingplatform.google.com/about/analytics/terms/us/ , part 7, Privacy
AppMetrica - https://metrica.yandex.com/about/info/privacy-policy
AppsFlyer - https://www.appsflyer.com/services-privacy-policy
Advertising cookies - These cookies are used to make advertising messages more relevant to the Client. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the Client’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.
List of relevant providers:
Google Advertising https://policies.google.com/privacy ( www.google.com/settings/ads to opt out from the Google Ads)
AppLovin https://www.applovin.com/privacy/
Appmetrica https://metrica.yandex.com/about/info/privacy-policy
MyTarget https://target.my.com/optout/
Mopub https://www.mopub.com/legal/privacy/
IronSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Vungle https://vungle.com/privacy/
Inmobi https://www.inmobi.com/privacy-policy/
Tapjoy https://www.tapjoy.com/legal/advertisers/#privacy-policy
AdColony https://www.adcolony.com/privacy-policy/
Social networking cookies - These cookies are used to enable the Client to connect the Client’s account to third party social networks.
List of relevant providers:
Facebook https://www.facebook.com/policy.php
Vkontakte https://vk.com/privacy?eu=1
Ok.ru https://ok.ru/res/privacypolicy.html
9.6. Below is information about how the Company uses Clients’ cookies on the the Company.me website:
Necessary - Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Name : cfduid, CookieConsent
Provider : HTTP Cookie
Purpose : cfduid: Used by the content network to identify trusted web traffic.,
CookieConsent: Stores the user's cookie consent state for the current domain.
Expiry :
Type : Necessary
10. Cross-border data transfer
10.1. Disclosure of the Company’s Clients’ Personal Data, as provided in section 6 of these Terms of Use sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. The Company uses standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the European Economic Area to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of Client’s Personal Data.
11. Service Provider
We may engage third-party companies to assist in delivering our Service, including analytics, advertising, and customer support. These Service Providers have access to your data only to perform specific tasks on our behalf and are obligated not to disclose or use it for other purposes.
12. Links to Other Sites
Our Service may link to other websites not operated by us. We advise you to review their privacy policies. We are not responsible for the content or practices of any third-party sites you visit and assume no responsibility for the content or practices of any third-party sites or services.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Behavioral Remarketing
the Company uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices , the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/ , or opt- out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
Customer support
the Company may use third party customer support services to provide customer support within the Service.
13. Children’s Privacy
Our Service is not intended for users under 18 years of age. We do not knowingly collect data from children under 18 years. If we learn that we have collected such data, we will take necessary steps to remove it.
14. Changes to This Privacy Policy
We may update this Privacy Policy periodically. Changes will be posted on this page, and you will be notified through prominent notice on our Service prior to the change taking effect.
Privacy Notice for California Residents
Effective Date: November 25, 2024
This Privacy Notice for California Residents supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"), as amended, and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
1. Information We Collect
In the course of providing our services, we collect personal information from or about consumers. This information includes the categories listed below, as defined by the CCPA, and is collected as described in Section 3.1 of our Privacy Policy.
Categories of Personal Information Collected
2. Sources of Personal Information
We collect personal information directly from you, automatically when you use our Services, and from third-party sources such as social networks.
Direct Collection
Personal information provided by you when:
Automatic Collection
Personal information collected through your use of our services, such as:
Third-Party Collection
Personal information received from third-party social networks when you connect your Account, including:
3. How We Use and Share Personal Information
The purposes and ways of use of personal information are described in correspondent provisions of Privacy Policy.
We may disclose your personal information to a third party for a business purpose to:
In the past 12 months, we have disclosed the following categories of personal information for business purposes:
In the preceding twelve (12) months, we have not sold any personal information.
4. Your Rights Under the CCPA
As a California resident, you have specific additional rights to the rights described in Privacy Policy regarding your personal information. These include:
Right to Know
You have the right to request details about the personal information we collect, use, disclose, and share.
Right to Delete
You can request that we delete your personal information, subject to certain exceptions, such as when the information is necessary to:
Right to Opt-Out
You have the right to opt-out of the sale or sharing of your personal information. While we do not "sell" personal information as traditionally defined, certain uses of advertising identifiers may be considered "sharing" under the CCPA.
Right to Non-Discrimination
You will not receive discriminatory treatment for exercising your rights under the CCPA.
5. How to Exercise Your Rights
To exercise your rights described above, please submit a verifiable consumer request by contacting us at: Email: [email protected] .
We will respond to verifiable requests within the timeframe required by law. If necessary, we may request additional information to verify your identity.
6. Data Retention
We retain personal information only as long as necessary for the purposes described in our Privacy Policy or as required by law. For more details on our data retention practices, please see the relevant sections of our Privacy Policy.
7. Changes to This Privacy Notice
We reserve the right to update this Privacy Notice at any time. If we make material changes to this notice, we will notify you by email or through a prominent notice on our App.
8. Contact Us
If you have questions or concerns about this Privacy Notice, please contact us at [email protected]
By using our Apps and Services, you agree to the practices described in this Privacy Notice.