Last Updated: February 7, 2020
1. What personal information do we collect?
a) Information You Provide. We may collect personal information from you when you voluntarily provide it to us through a number of features available on the Chater Software. For example, when you register, use, pay to use or subscribe to any of our Chater Services or take part in any interactive features of the Chater Services (such as any contests, games, promotions, quizzes, surveys, research or other services or features), we collect a variety of personal information directly from you or when you authorize us to access certain personal information. This information includes your birth date, name, age, gender, photographs, lifestyle, physical appearance, relationship intentions, bio, religion, political views, dating gender preference, education, language, interests (movies, TV shows, books, etc.) and profile pictures, valid email address and phone number, and your choice of username and password when you register for a Chater Account via email, etc. You may also be asked to validate your Chater Account via email, SMS or photo with required posture. We retain passwords in hashed format only.
b) We may also ask for other personal information as indicated on the relevant forms on the Chater Services. Where possible, on these forms we will indicate which fields are required and which fields are optional.
c) In addition, as you use the Chater Services, you can from time to time enter or send to us personal information such as sending us feedback via email. Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose. Once registered, you are no longer anonymous to us and you can review and change certain personal information such as your bio and gender in the Edit Profile settings area.
d) Information From Content You Post. When you post photos or other content to the Chater Services, we collect information such as the time and date the content was taken or uploaded. We reserve the right to collect data on how you use them, who views them or with whom you share.
e) Geolocation Data. When you use the Chater Services, we will collect your location information to determine your distance from other Users (" Distance Information ") through GPS, Wi-Fi and other cellular technology in your mobile device or through an Internet Protocol (" IP address ") address (which is a number that is automatically assigned to your computer or mobile device when you use the Internet, which may vary from session to session). Your last known location is stored on our servers for the purpose of calculating Distance Information between you and other Users. We will also collect your mobile device's geographic location data (including GPS) or your computer's geographic location data while the Chater Service is actively running. Sophisticated users who use the Chater App in an unauthorized manner, or other users who change their location while you remain in the same location, may use this information to determine your exact location and may be able to determine your identity. Please note: even if you choose to hide your Distance Information, the Chater App will continue to sort and display your profile based on your relative distance from other users, so your Distance Information may still be approximated by other users. Thus, even if you choose to hide your Distance Information, others may nevertheless be able to determine your location.
f) Information Automatically Collected. When you access the Chater Services, we automatically record information from your computer and/or mobile device and its software, such as your IP address, browser type, Internet service provider, platform type, the site from which you came and the site to which you are going when you leave, date and time stamp and one or more Cookies (as defined below) that may uniquely identify your browser or your Chater Account. Your mobile device's unique device ID is unique to the mobile device on which you install the Chater Services (" Device ID " and " Mobile Device ", respectively). For example, if you installed the Chater app on an Apple Device, we store your identifier for vendor. We create a hashed version of your Device ID and use your hashed Device ID to log you into the Chater Services. We store your Device ID and/or your hashed Device ID with other information we collect about you, including your Chater Account and profile information and your Message information. We will also collect certain software and hardware information about your Mobile Device. When applicable, we will also receive or collect identification numbers associated with your Mobile Device (such as an Open UDID), mobile carrier, device type, firmware version and manufacturer and other diagnostic Mobile Device information.
g) Information About How You Use The Chater Services. Additionally, we also automatically track certain personal information about you based upon your behaviour on the Chater Services, including information about your computer or Mobile Device and your activities. We create a tracking ID unique to each Chater Account for internal tracking purposes. We use this information to do internal research on our Users' demographics, interests, and behaviour to better understand, protect and serve you and our community. This may include information such as the pages and profiles you view, how you browse the Chater Services, your Chater Coin balance and purchases you make through the Chater Services. It can also include the various functions and features that you use, such as Messages (as defined below), the connections you make, other friends or contacts you invite to the Chater Services and profile searches you perform, or your general use of the Chater Services.
i) Messages. When you send a message (which may include text, photos, audio or video) to other Users of the Chater Services, we will retain the messages (" Messages ") as required by the operation of the Chater Services.
l) Your Communications With Us And Other Users. We collect communications you send to us (such as emails), comments that you post on the pages that we have on a third-party service such as our Instagram, Pinterest, Twitter and Facebook channels, and messages or communications you send to us directly through those services. We may also collect any comments, photos, messages or other content or communications you and other Users share on the Chater Services. If you provide us feedback or contact us via email (e.g., for support), we will collect your name and email address, as well as any other content included in the email in order to send you a reply. If you contact us for support, we may also collect and retain certain technical diagnostic data (e.g., your Mobile Device model).
n) Information Provided By Others. We may be provided with information relating to you or your conduct on the Chater Services by other Users of the Chater Services. We also collect information that third-party organizations may provide to us, such as demographic information or fraud prevention information.
2. How do we use the personal information that we collect?
a) Providing the Requested Chater Services: We use your personal information to administer and maintain your Chater Account and generally provide the functions and features that are part of the Chater Services (including providing communications as described below).
b) Analyzing and Develop Our Products and Services: We use your personal information to develop, deliver, measure, monitor, analyze and improve the Chater Services and develop new products and services.
c) Communicate With You: We use your personal information to respond to your comments and questions and provide customer service, to provide any messaging or communications associated with the functions and features of the Chater Services (including by email), to keep you posted on our latest product or service announcements or updates, software updates, security alerts and any technical notices and to provide you with support and administrative messages. If you do not wish to receive email from Chater you may opt-out by following the instructions included in each communication or by contacting Chater support at firstname.lastname@example.org.
d) Protect the Chater Services and Chater's Property: We use your personal information to detect and prevent abusive, fraudulent, malicious or potentially illegal activities, and to protect the rights, safety or property of Chater and our Users.
e) Geographical Or GPS Location-Based Services: We may use your personal information to provide features of the Chater Services that may be relevant to you and your geographical location or GPS information.
f) Additional Uses: We may use your personal information to perform other functions as may otherwise be described to you at the time of collection or as enabled by you in relation to the Chater Services.
3. How do we disclose your personal information?
The Chater Services allow you to share personal information about yourself with other individuals and other companies, including other Users and potential Users of the Chater Services. Please consider your own privacy and personal safety when sharing your information with anyone, including information you share through your profile. Profiles may include certain personal information that was provided at registration, and other information added by you (e.g., your bio), as well as information about your use of the Chater Services (e.g., whether you were recently logged in to the Chater Services). for tips on using the Chater Services.
Please be advised that information on your profile, including any personal information, is viewable by other Users. We do not control who reads the information that you share or what others may do with this information, so we encourage you to use discretion and caution with respect to your personal information. Also, if you wish to share information about other Users, please consider their safety and privacy and get their consent before sharing.
Except as described below, we do not sell, transfer or otherwise disclose to third parties the personal information we collect through the Chater Services. At times we may share personal information with third parties as follows:
1. With third party vendors, consultants, business partners and other service providers (" Third Party Providers ") that perform services on our behalf, in order to carry out their work for us, which may include identifying and serving advertisements, providing fraud detection services or providing analytics services;
2. With Third Party Providers that offer a service to you jointly with us, for example, if we run a contest or promotion.
Any Third Party Providers that have access to personal information are chosen carefully by us and are required to have privacy and security standards that meet our requirements. We use contracts and other measures with our Third Party Providers to maintain the confidentiality and security of Users' personal information and to prevent personal information from being used for any other purpose, including for any advertising or other commercial purposes. However, you should know that Third Party Providers performing services on our behalf may store, transfer and process personal information on servers located outside of Canada, in jurisdictions (including the United States) whose data protection laws differ from those of Canada. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Party Providers to maintain protections on personal information that are equivalent to those that apply in Canada.
We also reserve the right to transfer any personal information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, in connection with any company transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.
We may disclose your personal information for any other purpose to which you consent.
We reserve the right to share aggregated information (not linked to your personal information) with others that is not personal information or that is in an aggregated or anonymous form that does not reasonably identify you directly as an individual.
4. Our retention of your personal information
We retain personal information for only as long as required to fulfill the identified purposes for which it was collected, and for a reasonable time thereafter, or as required by law. Chater has retention standards which meet these requirements. Chater destroys your personal information following the end of our retention period, when it is no longer needed, or when we remove your name from the information. We assume no obligation or guarantee to archive any information and do not warrant that any archived information will later be made available to you.
You may deactivate your Chater Account at any time by accessing "Settings" and selecting deactivate account or by emailing our support team at email@example.com with the subject line Please Deactivate My Chater Account . After your Chater Account has been deactivated and you have logged out of the Chater Services, your profile will no longer be visible to other Users. If you do not reactivate your Chater Account within sixty (60) days, your Chater Account will be permanently terminated and closed but some information may remain in Chater's backup copies and logs for up to one (1) year.
For greater clarity, Messages, photos, videos, text, comments and certain other information sent to Users may remain on the Chater Services after you deactivate your Chater Account.
5. Legal requests; emergencies; jurisdictions
In some cases, personal information that we collect may be stored or processed by us outside of Canada in jurisdictions whose data protection laws may differ from Canada. In such cases, we will continue to protect the information with appropriate safeguards through contract and otherwise use reasonable efforts to ensure that appropriate protections are in place, but you acknowledge that your personal information may be subject to the governments, courts, law enforcement officials, national security authorities and laws of those countries.
Chater takes your privacy concerns seriously and strives to protect your personal information against unauthorized access, disclosure, inappropriate alteration and misuse. For security we use the Secure Sockets Layer (SSL/TLS) protocol for any transactions that send personal information. This encryption process protects your information, by scrambling it before it is sent to us from your Mobile Device or computer. We also make reasonable effort to ensure the security of your personal information on our system using available protection technology. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we make no representations or warranties as to the security of any information that you submit to us electronically in connection with the Chater Services, which you do at your own risk.
7. Advertising and Third Party Advertising Networks
We may use or share certain information with online advertising networks or similar third party vendors that display ads through the Chater Services, or to our Users. Typically, the information we share is provided through Cookies or similar technologies and is used to recognize the device or browser you are using. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests.
8. Access to your information and account management
You may access and change your Chater Account information at any time by visiting the " Edit Profile " and " Settings " sections of your Chater Account or the Social Networking Sites that you have connected to the Chater Services. You may also contact us for assistance using the details below if you want to access or change your Chater Account information or close your Chater Account.
9. Age restrictions
You are required to be at least 18 years old to use Chater so we do not intentionally collect personal information from anyone under 18, and no one under 18 should attempt to submit any personal information to Chater. If you suspect that a user is under the age of 18, please immediately click on the Report button located in the drop down menu on a User's profile or contact us using the details of the user.
10. Links to third party websites
11. YOUR RIGHTS
We want you to be in control of your information, so we have provided you with the following tools:
· Access / Update tools in the service. 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 service. If you have any question on those tools and settings, please contact our customer care team for help here.
· 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 on the service.
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 by sending us an email.
· 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 here.
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.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.
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 service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
· 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 re-install 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.
12. RESIDENTS OF CALIFORNIA
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.
13. HOW WE PROTECT YOUR INFORMATION
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
14. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of six months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, 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);
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 timeframe due to technical constraints.
16. Contacting Chater