Privacy Policy

1. Introduction

   1. We are committed to safeguarding the privacy of our service users.
   2. This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
   3. Your use of our service manifests your consent to transmission of personal data specified in this policy.
   4. This policy describes:
      • What data we collect
      • How we use your data
      • How we share and disclose your data
      • How we transfer data to other countries
      • How we retain your data
      • How to delete your data
      • How we protect your data
      • How to report security vulnerabilities in our system
      • Changes to our Privacy Policy
      • Cookies policy
      • External URLs policy
      • Special note for parents
      • Special note for kids
      • How to contact us

2. How we use your personal data

   1. We may collect, process, retain, and transfer different kinds of personal data:
      Type / Category

      Source

      Data

      Client data

      Internet connection

      • IP address
      • Country code (identified by IP address)

      Browser data

      Internet browser

      • Browser type
      • Browser version
      • Operating system and platform
      • Browser plug-in types and versions
      • Сameras and microphones list
      • Timezone
      • Browser language / locale

      Internal data

      Our system / database

      • Internal user ID

      Facebook data

      Facebook social network

      • ID
      • Gender
      • Birthday date
      • Location (country code and city)
      • Hometown
      • E-mail

      VKontakte data

      VKontakte social network

      • ID
      • Gender
      • Birthday date
      • Country
      • City
      • E-mail

      Device data

      Mobile device

      • Manufacturer
      • Model
      • OS version
      • Internet connection info
      • Device ID (Serial number, IMEI number, MAC address or phone number)
      • OS language / locale

      Videochat data

      User

      • Video/audio stream
      • Gender
      • Search country
      • Chat messages
      • Picture

      Settings data

      User

      • Locale settings
      • Translation settings

      Transaction data

      PayPal, Google Play

      • Transaction ID or purchase token
      • Order details (order ID, product ID, price, order date, etc.)
      • PayPal payer ID
      • PayPal payer E-mail
      • PayPal payer name
      • PayPal payer country code

      Correspondence data

      User, service contact forms

      • E-mail
      • Message
      • Metadata
      • Files and attachments

      Usage data

      Internet connection, HTTP protocol, internet browser

      • Google Analytics data (shortened IP address & website activity)
      • Cloudflare data (IP address & traffic logs)

      See “See Section 3” below

   2. We may use with the following purposes:
      Purpose

      Type / Category

      To display our website and maintain the connection with our application

      • Client data

      To properly run our website in different browsers and on different platforms

      • Client data
      • Browser data

      To properly run our application on different versions of Android

      • Client data
      • Device data

      To register a new user or log in registered user on our website

      • Client data
      • Internal data
      • Facebook data
      • VKontakte data

      To register a new user or log in registered user in our application

      • Client data
      • Internal data
      • Facebook data
      • VKontakte data
      • Device data

      To process and deliver user orders, manage payments, fees, charges

      • Client data
      • Transaction data

      To communicate with our users

      • Client data
      • Correspondence data

      To enable our users to participate in video chat

      • Client data
      • Internal data
      • Browser data
      • Facebook data
      • VKontakte data
      • Device data
      • Videochat data
      • Settings data
      • Usage data

      To grant personalized content for our users

      • Client data
      • Internal data
      • Facebook data
      • VKontakte data
      • Device data

      To properly administer and protect our system

      • Client data
      • Browser data
      • Device data

      To improve our service and user experiences

      • Client data
      • Browser data
      • Device data
      • Usage data
   3. The Facebook Platform Data includes an essential amount of the user's personal data. Below, we outline in more detail the purposes of this data usage. We might use the Facebook Platform Data for the following:
      Purpose

      Data

      • To authenticate users
      • To block offending users from using the service

      • User ID (unique for our service, part of Public Profile, auto granted by Facebook)

      • To match the Facebook and VK logins with the purpose of assigning them to the same account

      • E-mail (part of Public Profile, auto granted by Facebook)

      • To provide a personalized user experience based on Platform Data.

      • Gender
      • Birthday date
      • Location (country code and city)
      • Hometown
   4. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
   5. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
   6. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
   7. Please do not supply any other person's personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

   1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
   2. Financial transactions relating to our service may be handled by our payment services providers, PayPal, Google, VK. We will share transaction data with our payment service providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
   3. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
   4. Our service may require a direct connection to be made between your computer and the other user's computer. To do this, it is necessary to make your IP address available to the other user's computer, although it is not shown to the other user by service’s interface. This is a necessary part of how any peer-to-peer system functions.

   5. We use the functions of the web analytics service Google Analytics on our website to analyse user behaviour and to optimise our website. The provider of this service is Google Ireland Limited, Barrow Street, Dublin 4, Ireland ("Google").

      Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

      Google Analytics uses cookies that enable an analysis of the use of our website.

      In general, information about your use of the website is transferred to a Google server and stored there, such as the type and version of browser you used, the operating system you used, the site you visited prior to accessing our site, the host name of the computer (IP address) you used to access the site, and the time of your server request.

      At our request, Google will use this information to analyse the use of our website, to create reports on the activities within our website and to render additional services related to the use of our website and of the internet. According to Google, the IP address submitted by your browser will not be added to other data held by Google.

      During the website visit, the following data is collected:

      • the pages you call up, your "click path"
      • Achievement of "website goals" (conversions, e.g. newsletter registrations, downloads, purchases)
      • Your user behavior (for example clicks, duration of stay, bounce rates)
      • Your approximate location (region)
      • Your IP address (in shortened form)
      • technical information about your browser and the end devices you use (e.g. language settings, screen resolution)
      • Your internet provider
      • the referrer URL (via which website / via which advertising medium you came to our website)

      The data about the use of our website is immediately deleted after expiration of the storage limits that we have set. Google Analytics gives us the following options for the storage limits: 14 months, 26 months, 38 months, 50 months or no automatic deletion. You can ask us any time for the current storage limit that we have set.

      The processing of your data using Google Analytics is subject to your explicit consent in the sense of Art 6 paragraph 1 lit. a of the GDPR. You can revoke your consent at any time with effect for the future.

      You can also block the collection of data by downloading and installing the browser plugin available through the link below: http://tools.google.com/dlpage/gaoptout

      You can find out exactly where Google data centres are located here: https://www.google.com/about/datacenters/inside/locations/

      For more information about how Google uses your data, and about options for settings and withdrawal of consent, refer to the Google Privacy Policy at https://policies.google.com/privacy

   6. On our website Cloudflare is used as a so-called content delivery network (CDN). Cloudflare is a service of Cloudflare Inc., 101 Townsend Street, San Francisco, California 94107, USA, ("Cloudflare").

      Within the scope of this service, data is transferred to the US or such a transfer cannot be excluded.

      A CDN is a service that helps us to provide content from our website, especially large media files, such as images, by using regional and Internet-connected servers to be delivered faster. Delivering content through servers near you reduces average website load times.

      Cloudflare contributes both web optimization and security services. Cloudflare blocks threats and limits misuse of server resources and bandwidth. Our website is significantly more powerful and less vulnerable to spam or other attacks thanks to Cloudflare.

      Cloudflare uses cookies and processes data of our website users.

      If you visit our website, your requests will be directed by the server of Cloudflare. In this case, statistical access data is collected when visiting our website.

      Access data includes:

      • your IP address,
      • the addresse(s) of our website you have visited,
      • type and version of the internet browser you are using,
      • the operating system you are using,
      • the website from which you have switched to our website (referrer URL),
      • the time of your stay on our website and
      • the frequency of calling our websites.

      This data helps Cloudflare in particular to detect new threats and to ensure a high security standard for the operation of our website.

      Your data is processed to maintain the security and functionality of the CDN and to optimize our loading times. The use of cookies by Cloudflare is done for security reasons to ensure the trustworthiness of an end device and is absolutely necessary for the security function.

      Cloudflare keeps data logs only as long as necessary and this data is deleted within 24 hours in most cases. However, there is information that Cloudflare keeps indefinitely as part of its permanent logs in order to improve Cloudflare's overall performance. However, this data is not personal and is anonymized by Cloudflare. What data is involved can be found at https://www.cloudflare.com/application/privacypolicy/

4. International transfers of your personal data

   1. The hosting facilities for our service are situated in Germany (European Economic Area).
   2. Users of our service are located in multiple countries, including the European Economic Area. We have developed data practices designed to assure information is appropriately protected but we ask you to be aware of the privacy and data protection laws in the jurisdiction in which you reside. As otherwise stated in this policy, you acknowledge that, the ultimate responsibility for the information you choose to share is yours.
   3. You acknowledge that personal data that you submit for publication through our service may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

   1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
   2. We will not retain your complete message data (message log). We store none outgoing or incoming messages, and these data cannot be retrieved or restored. We will retain specific messages in ban data for bans related to inappropriate behavior in the text chat.
   3. We will retain your ban data as long as it is necessary to maintain the ban technically for a determined period. We will not keep user image after ban expiration, but will retain a record about this specific ban.
   4. We will not retain your communication data. We store none information related to with whom and when you communicated, and such information cannot be retrieved or restored.
   5. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
   6. Within our Android application, you can delete your profile using the appropriate in-app function, which is available in the application settings section. To access the settings, tap on the gear icon located in the top right corner of the partner video window after launching the application or when the conversation is paused. Upon deletion, your account will immediately become publicly inaccessible. Any data associated with your profile, including photos, messages, subscriber list, etc., will also become inaccessible, yet will be physically deleted from our servers 30 days following the profile deletion.
   7. You may submit a request to delete your data by using the form at https://chatruletka.com/account-deletion/. After proper verification procedures, we will process your request in accordance with applicable laws as soon as practicable.

6. How we protect your personal data

   1. We employ proper technical and physical measures to protect the personal data of our users from loss, destruction, change, unauthorized access, disclosure, or any other illegal forms of processing.
   2. We employ a modern means of protection for the personal data of all users according to the current state of the industry. We use a secure server software (SSL) to encrypt user data before it is sent to us, and our database is hosted in a secure data center.
   3. Only authorized personnel have access to user data.

7. Security vulnerabilities reporting

   1. We pay much attention to the proper security of personal data. Despite this, a weak spot may exist or develop. If you believe you have discovered a security or privacy vulnerability when using our services, please send us an email at [email protected] with a detailed description. We will contact you if we need more information.

8. Amendments

   1. We may update this policy from time to time by publishing a new version on our website.
   2. You should check this page occasionally to ensure you are happy with any changes to this policy.

9. About cookies

   1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
   2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
   3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

    1. We use cookies for the following purposes:
       (a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;
       (b) analysis - we use cookies to help us to analyze the use and performance of our website and services;

11. Cookies used by our service providers

    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    2. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/ .
    3. We use Facebook Like Button widget to share the information about our service on Facebook. When visiting our website containing such a widget, your browser will establish a direct link with the servers operated by Facebook; as a result the content of the widget will be transferred to your browser and embedded in the website being shown. If you visit our website whilst signed into your Facebook user account, information concerning your visit will be transferred to Facebook. Facebook can assign your visit to our website to your user account. Information arising from interaction with the Facebook widget (such as by clicking the Facebook “like” button or by leaving a comment) will be directly transferred to and stored by Facebook. To prevent this, you must log out of your Facebook account before visiting our website. Please refer to Facebook’s privacy policy (https://www.facebook.com/privacy/explanation) for more information on: the purpose and scope of data collection and data analysis undertaken by Facebook, your rights, how to modify settings and how to protect your privacy.
    4. We use Twitter Tweet Button widget to share the information about our service on Twitter. Twitter uses cookies for purposes described at https://help.twitter.com/ru/rules-and-policies/twitter-cookies. You can view the privacy policy of Twitter provider at https://twitter.com/ru/privacy.

12. Managing cookies

    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
    2. Blocking all cookies will have a negative impact upon the usability of many websites.
    3. If you block cookies, you will not be able to use all the features on our website.

13. External URLs

    1. We reserve the right to place external links to websites and third party goods throughout our service.
    2. We attempt to always provide links and URLs to respected websites, however, we do not accept responsibility for any contents, security, or actions taken on such websites.
    3. When you navigate to any third party website, any personal data that you provide is managed exclusively by the privacy policy of that particular website and we do not assume any responsibility for the data you decide to provide.

14. Special note for parents

    1. While we encourage children to consult with their parents before furnishing personal data, parents should supervise their children’s online activities and consider using parental control tools available from online services and software manufacturers.

15. Special note for kids

    1. Be sure to ask your mom or dad for permission before sending any information about yourself to us (or anyone else) over the Internet.

16. Contact

    1. If you have any questions about this policy, please contact us by email: [email protected]. Letters sent to this address and not related to the privacy policy may be ignored.

Last updated: 27/10/2021