Privacy Policy

Effective Date: March 3, 2025
Welcome to Cokiy! This Privacy Policy explains how we collect, use, and safeguard your personal information when you use our application (“Application”), website, and related services (collectively, the “Services”). By registering an account, accessing, or using our Services, you confirm that you have read, understood, and agree to this Privacy Policy, as well as our User Terms and Conditions, Copyright Policy, and Publisher Terms. If you disagree with any part of this policy, please refrain from using our Services.

1. Controller and Data Protection Officer

Controller:

￮ Name: Bastien Dassonville

￮ Contact Address: Kranichsteiner Str. 81, Frankfurt am Main-60598, Germany

￮ Email: bastiendassonville7@gmail.com

Bastien Dassonville is the data controller responsible for processing your personal information. You can reach us via email at bastiendassonville7@gmail.com.

Data Protection Officer (DPO):

￮ Name: Bastien Dassonville

￮ Contact Address: Kranichsteiner Str. 81, Frankfurt am Main-60598, Germany

￮ Email: bastiendassonville7@gmail.com

2. Information We Collect

To provide high-quality, personalized services and ensure a smooth user experience, we collect the following types of information:

2.1 Account Information

When you register an account, we collect essential personal details such as your username, profile picture, date of birth, and country of residence. This information helps us create a customized user profile tailored to your preferences, ensuring you receive a relevant and enjoyable experience on our platform.

2.2 Device Information

To ensure the proper functioning, security, and compatibility of our application, we collect detailed information about your device. This includes the device type, operating system, hardware configuration, IP address, network details (such as connection type and service provider), and Device ID. This data enables us to deliver a stable and secure experience across various devices and platforms.

2.3 Log Data and Analytics

We gather comprehensive log data, including your IP address, device type, browser information, access times, system activity, and advertising ID. This information helps us monitor service performance, diagnose technical issues, and identify areas for improvement. Additionally, we use analytics to evaluate the effectiveness of our features, marketing strategies, and service enhancements, ensuring we provide you with the highest level of quality and personalization.

By collecting and analyzing this information, we strive to create a secure, efficient, and user-centric experience that meets your needs and exceeds your expectations. We are committed to handling your data responsibly and transparently, always prioritizing your privacy and trust.

The inclusion of the advertising ID allows us to better understand user interactions with advertisements, optimize ad delivery, and provide more relevant and personalized content. Rest assured, all data collection and usage practices adhere to strict privacy standards and applicable regulations.

3. How We Use Information

We utilize the collected information for the following purposes:

3.1 Providing and Enhancing Services

￮ Social Interactions: Enhance features to facilitate connections with other users and enable discovery of relevant content.

￮ User Support: Deliver prompt technical assistance tailored to your device and usage patterns.

￮ API Requests and Analytics: Track and refine application performance and functionality to ensure optimal user experience.

3.2 Security and Protection

￮ Fraud Detection and Prevention: Identify and mitigate suspicious activities to safeguard our community.

￮ Data Security: Implement stringent measures to protect your personal information from unauthorized access or breaches.

3.3 Communication and Notifications

Send essential updates, policy changes, and security alerts to keep you informed about developments affecting your use of our services.

3.4 Analytics and Improvement

￮ Analyze user behavior to refine our services and introduce innovative features.

￮ Collect and review log data to diagnose issues and optimize performance.

4. Information Sharing

At Cokiy, we prioritize your privacy and are dedicated to ensuring the security of your personal information. We do not sell, rent, or share your personal information without your explicit consent, except in the specific scenarios detailed below:

4.1 With Your Consent

We may share your personal information with third parties if you grant explicit permission. This could involve collaborations with partners, advertisers, or other entities for purposes such as personalized services, promotions, or joint initiatives. Before sharing any data, we will always seek your consent and provide clear information about the purpose and scope of the sharing.

4.2 Legal Requirements

We may disclose your personal information when required by law, regulation, or legal processes. This includes responding to subpoenas, court orders, or government requests. Additionally, we may share information to enforce our terms of service, protect our rights, or ensure the safety of our users, employees, or the public.

4.3 Sharing with Service Providers

We work with trusted third-party service providers to enhance the functionality, security, and quality of our services. These partners include, but are not limited to, data analytics platforms (e.g., Appsflyer), marketing optimization tools (e.g., Facebook), and payment processors. These providers are rigorously vetted and bound by strict confidentiality agreements to ensure your information is handled securely and in compliance with applicable privacy laws.

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the transaction. If such a transfer occurs, we will notify you of the change and provide details about how your information will be managed. We will also ensure that the receiving party adheres to the same privacy standards and protections outlined in this policy.

4.5 Aggregated or Anonymized Data

We may share aggregated or anonymized data that does not directly identify you with third parties for purposes such as research, analytics, or marketing. This data is used to improve our services, develop new features, and better understand user trends while maintaining your privacy.

4.6 Protection of Rights and Safety

We may share your information if we believe it is necessary to protect the rights, property, or safety of Cokiy, our users, or the public. This includes sharing information to prevent fraud, address security breaches, or respond to emergencies.

4.7 International Data Transfers

If your personal information is shared with third parties located in countries outside your jurisdiction, we will ensure that appropriate safeguards are in place to protect your data. This may include implementing standard contractual clauses or ensuring the recipient is certified under recognized privacy frameworks.

By using Cokiy, you acknowledge and agree to the sharing of your information as described in this section. We are committed to maintaining transparency and ensuring that your data is shared responsibly and in accordance with applicable laws and regulations.

If you have any questions or concerns about how your information is shared, please contact us at bastiendassonville7@gmail.com.

Permissions Explanation

To ensure full functionality, we may request the following permissions:

• Microphone: For voice messages and video calls.

• Camera: For profile picture uploads and live video calls.

• Photo Library: To share images and customize your avatar.

• External Storage: To manage content on your device.

• Bluetooth: For audio recording and real-time communication.

• Advertising IDs: For marketing optimization and campaign analysis.

These permissions are only used with your explicit consent and can be managed in your device settings.

6. Information Security

We implement a multi-layered approach to safeguard your personal information, incorporating access controls, continuous security monitoring, and strict data retention policies. While we are committed to maintaining the highest security standards, no system is entirely immune to risks, and we cannot guarantee absolute security.

7. Your Rights

You are entitled to the following rights concerning your personal information:

You can exercise these rights through the application’s settings or by reaching out to our customer service team.

8. Legal Basis for Data Processing

We process your personal data based on the following legal grounds:

￮ Consent: When you provide explicit permission.

￮ Contractual Necessity: To fulfill our obligations under our agreement with you.

￮ Legitimate Interests: To enhance our services and ensure security.

￮ Legal Obligations: To comply with applicable laws.

￮ Public Interest: In cases involving public interest.

9. CCPA Rights (Applicable to California Residents)

Under the California Consumer Privacy Act (CCPA), California residents are granted specific rights to enhance their control over personal information. These rights aim to ensure transparency, accountability, and user empowerment. Below is a detailed explanation of these rights and the steps you can take to exercise them:

To exercise these rights, please contact us through the provided channels, and we will guide you through the process.

9.1 Right to Access Your Personal Information

The CCPA grants you the right to request detailed information about the personal data we have collected, used, shared, or sold over the past 12 months. This includes:

To exercise this right, you can submit a request through our designated channels, and we will provide the requested information in a clear and accessible format.

9.2 Right to Request Deletion of Your Personal Information

You have the right to request the deletion of your personal information, subject to certain exceptions. For example, we may retain your data if it is necessary to:

Upon receiving a valid deletion request, we will promptly remove your data from our systems and instruct our service providers and partners to do the same.

9.3 Right to Opt Out of the Sale of Personal Information

The CCPA defines "sale" broadly to include any disclosure or provision of personal information to a third party in exchange for monetary or other valuable consideration. You have the right to opt out of such sales at any time. To exercise this right:

Once you opt out, we will cease selling your personal information unless you provide explicit consent to resume such activities.

9.4 Right to Opt Out of Sharing Personal Information

Under California law, "sharing" refers to using personal information for targeted advertising based on user behavior. You can opt out of such sharing by:

Opting out of sharing will not affect your ability to use our Services but will limit the use of your data for advertising purposes.

9.5 Right to Non-Discrimination

The CCPA prohibits discrimination against users who exercise their privacy rights. This means we will not:

However, if you choose to delete certain information required for specific features, those features may no longer be available to you.

9.6 Right to Know if Your Data is Sold

You can request confirmation of whether your personal data has been sold to third parties. If we have sold your data, we will provide details about the categories of information sold and the recipients. You can also opt out of future sales at any time.

9.7 Right to Lodge Complaints with Local Authorities

If you believe we have violated your CCPA rights, you can file a complaint with the California Attorney General or other relevant authorities. We encourage you to contact us first to address your concerns, but you retain the right to escalate the matter if necessary.

10. LGPD Compliance (Applicable to Brazil)

The Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, or LGPD) grants Brazilian users specific rights to safeguard their personal data. Below is an in-depth explanation of these rights and how you can exercise them:

10.1 Right to Access

You have the right to request access to the personal data we hold about you. This includes:

￮ Categories of data collected.

￮ Purposes of processing.

￮ Third parties with whom the data is shared.
We will provide this information in a clear and accessible format upon receiving your request.

10.2 Right to Rectification

If you believe your personal data is inaccurate or incomplete, you can request corrections. We will promptly update your information and notify any third parties with whom the data has been shared.

10.3 Right to Erasure

You can request the deletion of your personal data, except when retention is necessary to:

￮ Comply with legal obligations.

￮ Protect public health or safety.

￮ Fulfill contractual obligations.
Upon receiving a valid request, we will securely delete your data from our systems.

10.4 Right to Data Portability

You can request a copy of your personal data in a structured, commonly used, and machine-readable format. This allows you to transfer your data to another service provider or use it for your own purposes.

10.5 Right to Object

You can object to the processing of your personal data based on legitimate interests. If we do not have compelling reasons to continue processing, we will cease the activity.

10.6 Right to Withdraw Consent

If we process your data based on consent, you can withdraw that consent at any time. This will not affect the legality of processing activities conducted before your withdrawal.

10.7 Right to Lodge Complaints

If you believe we have violated the LGPD, you can file a complaint with the Brazilian National Data Protection Authority (ANPD). We are committed to resolving any issues promptly and transparently.

11. GDPR Compliance (Applicable to EU/EEA Residents)

The General Data Protection Regulation (GDPR) provides users in the European Union and European Economic Area with robust rights to protect their personal data. Below is a detailed explanation of these rights and how you can exercise them:

11.1 Right to Access

You can request access to the personal data we hold about you, including:

￮ Categories of data collected.

￮ Purposes of processing.

￮ Third parties with whom the data is shared.
We will provide this information in a clear and concise manner.

11.2 Right to Rectification

If your personal data is inaccurate or incomplete, you can request corrections. We will update your information and notify any relevant third parties.

11.3 Right to Erasure

You can request the deletion of your personal data under certain conditions, such as when the data is no longer necessary for the purposes it was collected or if you withdraw consent.

11.4 Right to Restrict Processing

You can request that we restrict the processing of your personal data in specific circumstances, such as when you contest the accuracy of the data or object to its processing.

11.5 Right to Data Portability

You can receive your personal data in a structured, commonly used, and machine-readable format and transfer it to another controller.

11.6 Right to Object

You can object to the processing of your personal data based on legitimate interests or for direct marketing purposes. If we do not have compelling reasons to continue processing, we will cease the activity.

11.7 Right to Withdraw Consent

If we process your data based on consent, you can withdraw that consent at any time. This will not affect the legality of processing activities conducted before your withdrawal.

11.8 Right to Lodge Complaints

If you believe we have violated the GDPR, you can file a complaint with your local data protection authority. We are committed to addressing your concerns and ensuring compliance with the law.

12. VCDPA Compliance (Applicable to Virginia Residents)

The Virginia Consumer Data Protection Act (VCDPA) grants Virginia residents specific rights to protect their personal data. Below is a detailed explanation of these rights and how you can exercise them:

12.1 Right to Access

You can request confirmation of whether we process your personal data and access to that data, including the categories of information and the purposes of processing.

12.2 Right to Correct

If your personal data is inaccurate, you can request corrections. We will update your information and notify any relevant third parties.

12.3 Right to Delete

You can request the deletion of your personal data, subject to certain exceptions, such as legal obligations or the need to complete a transaction.

12.4 Right to Data Portability

You can obtain a copy of your personal data in a portable and readily usable format.

12.5 Right to Opt Out

You can opt out of the processing of your personal data for:

￮ Targeted advertising.

￮ The sale of your data.

￮ Profiling in furtherance of decisions that produce legal or similarly significant effects.

12.6 Right to Appeal

If we deny your request, you have the right to appeal the decision. We will provide a clear explanation of the reasons for the denial and instructions for filing an appeal.

13. Other Applicable Laws

Depending on your location, other national or regional privacy laws may apply. We are committed to complying with all relevant laws and regulations to protect your personal information. If you have questions about your rights under specific laws, please contact us for further assistance.

14. Children’s Privacy

Our Services are not intended for users under 18. We do not knowingly collect personal information from minors. If we discover such data, we will promptly delete it. Parents or guardians can contact us to request the removal of their child’s information.

15. Changes to the Privacy Policy

We may update this policy to reflect changes in our Services or legal requirements. Significant changes will be communicated through in-app notifications or by updating this page. Continued use of our Services after changes constitutes acceptance of the updated policy.

16. Contact Us

For questions, concerns, or to exercise your rights, contact us at:

Email: bastiendassonville7@gmail.com

Thank you for choosing Cokiy. We are committed to protecting your privacy and providing a safe, enjoyable experience.

This comprehensive Privacy Policy ensures transparency, compliance, and user empowerment by clearly outlining your rights and our responsibilities under various legal frameworks.