Privacy Policy

As a large social network platform, CozyPal allows users to share, experience AI dating matching, express emotions, show their true selves, and establish the best connections between people, all of which are closely related to personal data sharing. This Privacy Policy explains how CozyPal (hereinafter referred to as "we", "APP", or "CozyPal") collects, uses, stores, and protects your personal information. It is an inseparable part of the "CozyPal Terms of Service" and has the same legal effect as the terms of service. Your use of the service indicates that you have read, understood, and agreed to this policy. CozyPal is operated by TENSORIS TECHNOLOGY (HK) LIMITED, which is the data controller of your personal information. Please read this policy carefully, and if you have any questions, please feel free to contact us at cozypal@cozypal.chat.

By using CozyPal's services, you commit that:

1. You have read, understood, and agreed to this Privacy Policy;
2. You are at least 18 years old. If you do not agree or cannot make this commitment, you must not use the service. In this case, you must:
   1. Delete your account and contact us to request the deletion of your data;
   2. Cancel all subscriptions using Apple (if you use iOS) or Google (if you use Android), any other app store that may be available from time to time, or functions provided by us.

CozyPal or certain services you use to interact with the service may have their own privacy rules (third-party privacy policies). Therefore, if your personal data is processed by such services, such processing is subject to the third-party privacy policy and not this policy. Your "personal data" or simply "data" refers to any information related to you, or any information that may directly or indirectly identify you personally.

I. Privacy Tips

When using CozyPal, you should assume that all content you publish, share, or send on the APP may be publicly viewed and accessed by other CozyPal users and people outside the application. We hope you are careful about making your data public, therefore, we kindly ask you to follow these privacy recommendations:

1. When you publish information about yourself or use the messaging function, you share personal information at your own risk;
2. When you voluntarily disclose registration information (including your CozyPal profile), you will share information with other users. Therefore, we recommend and encourage you to carefully consider the personal information you disclose. Please handle your data with care and ensure that the information you publish is data you voluntarily make publicly viewable;
3. We do not recommend that you put URLs, instant messaging details, credit card details, and other important data in your CozyPal profile, or send these data to people you do not trust via direct messages;
4. We do not recommend that you share your sensitive information with other users, such as religious affiliation, sexual orientation, health status, political leanings, any addictive behaviors, precise geolocation information, race, etc.
5. The photos you share through CozyPal may reveal a lot of your information; before uploading or sharing photos, please check all photos for the presence of data or content you do not want to make public;
6. Please make sure to log out of your account after using your CozyPal profile on your or a third party's device; please do not share your access credentials on CozyPal, such as login name, password, etc., with anyone;
7. We kindly remind you that you are the only person who needs to pay attention to the security of your access credentials. Please remember that if your access credentials are stolen, a third party may obtain your data. If you lose control of your account and do not promptly inform CozyPal of the issue, we cannot guarantee the security of your data.
8. CozyPal allows you to share your personal information, including your educational information and information that may be considered "sensitive" or a "special category" in certain jurisdictions, such as religious beliefs. Only with your explicit consent, CozyPal collects only the information necessary to provide AI dating, radar matching, and AI chatting services, including:
   1. Registration and Identity Information: Name, age, gender, avatar, third-party login accounts (such as Apple, Google, Facebook);
   2. Profile Information: Interest tags, photos;
   3. Interaction and Behavioral Information: Chat history, AI chatting content, match records, voice call records, intimacy data, offline reports;
   4. Payment and Membership Information: Subscription status, order records, consumption amount, validity period;
   5. Device and Network Information: Device model, IP address, system version, network status;
   6. Sensitive Information (collected only when actively provided by you): Religious beliefs, race, sexual orientation.

9. Policy Changes

1. Reasons for Update. CozyPal may modify this policy from time to time based on new developments or advancements in legislation and the broader data protection landscape, so please check this page regularly to ensure you are always aware of any changes.
2. Update Notification. If CozyPal, at its sole discretion, makes any material changes to this agreement, CozyPal will post a notice within the APP before the changes take effect.

10. Your Data Controller and Data Processors: Service Providers, Contractors, and Third Parties Accessing Data

1. Information about who processes your data and with whom CozyPal may share your data is considered one of the most important points you should know, so CozyPal puts this section at the beginning of this policy. In this section, CozyPal also explains which third-party channels may be used to receive your data.
2. Roles and Definitions. The first thing you should know is information about data controllers and processors. A data controller is an entity that determines the purposes and means of data processing. A data processor is an entity that processes data on behalf of the controller. A third party is an individual who accesses data according to their rights or obligations.
3. Data Processors. When processing your data, CozyPal may use the following data processors:
   • Type: Infrastructure and Security
     Processor: Amazon Web Services
     Processor's Privacy Policy: https://aws.amazon.com/privacy/
     Collected Data: All personal data
     Purpose: Storage of all personal data when you use the application
   • Type: Moderation and Photo Verification Tool
     Processor: TENSORIS TECHNOLOGY (HK) LIMITED
     Processor's Privacy Policy: s://www.cozypal.chat/privacy
     Collected Data: Photos
     Purpose: Moderating content and helping verify users

11. Software Development Kits (SDKs)

In addition to the data processors mentioned above, your data may also be processed by other companies through SDK technology (they are also processors of your data). An SDK refers to a programming package or code library for a service that is integrated into the mobile apps of another service so that these apps can run on the SDK owner's specific platform. Please disclose the following information about them:

12. Additional Data Processors

If necessary, CozyPal's services may also involve other service providers, contractors, and third-party services, and may share data with them. This will help us operate, provide, improve, integrate, customize, support, and promote our services. We share data especially for the purposes described herein. The types of service providers we may share information with may include: cloud storage providers, data analytics providers, measurement partners, marketing partners, payment processing providers, communication service providers, etc.

13. Sharing Consumer Information with App Store

By registering on the CozyPal app, you agree that we share your information with the Apple Store (UUID of your in-app user account, your consumption status, the duration you use the app, platform type, and the amount you pay in-app) to help inform and improve the payment process. You can withdraw your consent at any time; please contact CozyPal at cozypal@cozypal.chat. If you request the deletion of your personal data, you can also visit privacy.apple.com to submit a request directly to Apple.

14. Moderation

We have established a data protection and account security audit mechanism to monitor and review accounts (including names and any other information uploaded to the user's profile). If a user's profile does not meet certain standards, indicating that the user may have violated the terms of use, the user's access will be restricted and/or blocked. Affected users can contact CozyPal to dispute the decision.

15. Third-Party Data Disclosure

CozyPal is a place free from any form of abuse, violence, and infringement of third-party rights. CozyPal is committed to creating a safe haven where users can fully be themselves and feel comfortable expressing their emotions. CozyPal does its utmost to protect the platform's greatest value—the users' sense of security—so we may disclose your data to third parties under the following circumstances:

1. CozyPal will cooperate with law enforcement investigations within or outside your country of residence, provided that CozyPal is required to do so by law, to investigate suspected criminal behavior or to protect significant personal interests. CozyPal may share any personal data held about you depending on the nature of the request or the issue CozyPal is dealing with;
2. If necessary, CozyPal will disclose your data to comply with judicial proceedings, court orders, or legal requirements from state agencies (legal protection or law enforcement agencies). CozyPal may share any personal data held about you depending on the nature of the request or the issue CozyPal is dealing with;
3. If CozyPal receives a notice of a user violation, it may also cooperate with all third parties to exercise its intellectual property or other rights. Even so, if CozyPal receives a relevant and well-founded legal request from a third-party lawyer, and the request only proves your violation, CozyPal will still share your data. CozyPal may share any personal data held about you depending on the nature of the request or the issue being dealt with. Please note that if CozyPal does not find sufficient evidence during the investigation, it will not disclose your data;
4. If CozyPal detects illegal activity, or CozyPal believes it is necessary to investigate, prevent, or take action regarding illegal activities, fraud, or situations posing a potential threat to anyone's safety, it may transfer your data to relevant legal protection or law enforcement agencies.
5. If CozyPal finds that your behavior violates the APP's Terms of Service or any of its components, or to protect the rights and property of CozyPal, its affiliates, or the public, or to comply with legal and regulatory obligations, CozyPal will share your data with engaged lawyers, courts, arbitrators, or any authorized professionals, etc.

16. CozyPal's Attitude Towards Minors' Privacy

1. Age Limit. This service is restricted to users aged 18 and above. We strictly comply with the Children's Online Privacy Protection Act (COPPA) and never intentionally collect information from minors under the age of 13. If we discover that a user under the age of 18 is using the service, we will immediately cancel the account and delete all data.
2. Prompt Notification. If CozyPal becomes aware that the APP has collected any personal information from a user under the age of 18 (or under the legal age of majority in their place of residence), we will process that information in accordance with the Children's Online Privacy Protection Act (COPPA) and other applicable laws and regulations. If you are a parent, guardian, or you believe a user is a minor, please contact us by emailing cozypal@cozypal.chat, or report it through the relevant function in the APP.
3. Processing Measures. If CozyPal discovers that a user under the age of 18 has registered on CozyPal and provided incorrect personal information to the APP, we will take measures to terminate the user's registration and delete all relevant registration data from CozyPal.

17. Artificial Intelligence Features

CozyPal's services may offer various AI features, such as AI agent tuning, radar matching based on personal data, and AI chatting. To this end, you understand and agree that CozyPal uses your profile, preferences, and interaction data to provide AI agent, radar matching, and AI chatting services. We only use desensitized and encrypted data to optimize the platform's AI algorithms, and absolutely do not use your plain-text chat records to train externally provided AI models; all AI processing is strictly limited to the purpose of providing services to you.

II. Modification and Deletion of Personal Information

CozyPal attaches great importance to the accuracy of the information you provide. All users can confirm, change, or delete the personal information you provided to CozyPal, all of which can be operated directly on the "Personal Center" page; deleted data cannot be recovered. If you need to delete personal information in batches, you can submit a request via email to cozypal@cozypal.chat, and CozyPal will process it within 15 days and provide feedback on the processing result. Deleting personal information does not affect your use of the core free features of the product; it will only clear related personalized data (such as historical match records).

III. Security Protection Measures for Information Collected by CozyPal

Although CozyPal has taken commercially reasonable technical and organizational measures in line with industry standards: CozyPal stores personal information (including sensitive personal information) in secure facilities with restricted access, and uses industry-standard firewalls and security software to protect the security and integrity of your personal information; CozyPal uses industry-standard AES-256 encryption technology to protect data, only authorized platform staff can access it, and access requires multi-factor authentication. CozyPal signs strict confidentiality agreements with platform staff; staff members who leak user information will bear corresponding legal responsibilities; CozyPal regularly tests and upgrades the data security system to prevent data leakage, tampering, or loss. However, internet data transmission and storage cannot be guaranteed to be 100% secure. For data security incidents directly caused by reasons other than CozyPal's failure to fulfill the security obligations described in this policy (such as force majeure, unforeseeable complex network attacks, etc.), CozyPal's liability will be limited only to the maximum extent permitted by law. By using this platform, application, and CozyPal services, you acknowledge and understand these risks and agree to bear them.

Your personal data is stored only during the existence of the account; after the account is cancelled, we will delete all your data within 15 days (except for those required to be retained by laws and regulations, and the retention period strictly complies with legal provisions).

IV. Cookies and Tracking Technologies Used by CozyPal

We only use necessary Cookies to maintain logins and service preferences, and do not use them for cross-platform advertising tracking; you can freely disable or delete the platform's Cookies through your browser's Cookie settings. Disabling them will only lead to the loss of account login status and the reset of service preferences, and will not affect the use of core product functions; when you log in to the APP for the first time, CozyPal will show you a Cookie usage prompt, and you can independently choose to agree or reject.

CozyPal does not allow any third party to deploy tracking technologies on this platform, does not share Cookie data with third parties, and does not collect any of your personally identifiable information through Cookies.

When you receive emails or notifications sent by CozyPal, CozyPal may use Cookies to determine whether the email has been opened and which links you clicked, in order to provide you with more targeted email communications or other information, and/or aggregate this information with other data collected by CozyPal for some or all of the purposes outlined in this Privacy Policy.

V. Your Rights Regarding the Processing of Personal Data Information

1.If you are a US resident, especially a California resident (governed by CCPA/CPRA), you enjoy the following personal data rights guaranteed by US privacy laws:

1. Right to withdraw consent: If you have agreed to CozyPal processing your personal information, you have the right to withdraw that consent at any time.
2. Right to know: You can apply via email at cozypal@cozypal.chat to obtain a list of all your personal information collected by CozyPal, the purpose of use, and disclosure details.
3. Right to delete/erase: You can request CozyPal to delete all collected personal information about you. Please note that exercising the right to delete may result in you being unable to access your account and any check-in records, leaderboard information, or features associated with it. If you wish to cancel your account or request CozyPal to stop using some or all of your information to provide services to you, you can send an email to cozypal@cozypal.chat. CozyPal will initiate the processing procedure within 10 business days after receiving a verifiable consumer request. For complex requests, the processing time may be appropriately extended, but CozyPal will notify you of the reason for the extension and the estimated completion time within this period.
4. Right to correct: If you find that any personal information processed by CozyPal is inaccurate, you can contact CozyPal to correct it. CozyPal will cancel or delete your information, but may retain and use a copy of your information as needed to fulfill CozyPal's legal obligations, resolve disputes, and enforce CozyPal's agreements.
5. Right to object to processing: Under specific circumstances, you can object to our processing of your personal information through CozyPal's privacy portal. After objecting to processing, you may be unable to access some or all of CozyPal's services. This right is limited to personal data processed for commercial purposes.
6. Right to object to the use of sensitive personal information: You have the right to object to CozyPal using your sensitive personal information. Sensitive personal information refers to information about your health status, race, religious beliefs, sexual orientation, gender identity, political opinions, or philosophical beliefs. You should always be cautious about the personal information you share online, especially some sensitive information.
7. Right to object to automated processing: You have the right to object to your data being used to make automated decisions about you.
8. Right to non-discrimination: You have the right to not be discriminated against when exercising your rights.

2.Right to complain (limited to users in the EU, UK, and Switzerland): If you believe that CozyPal violates relevant laws and regulations and infringes your legitimate rights when processing your information, and you wish to file a complaint about CozyPal’s collection or use of your information, you have the right to do so, and it will not affect any other rights you may have. You can file a complaint with your local data protection authority.

3.Authorized Agent Rights (limited to users in California): If you wish to submit a request on behalf of a California consumer, please provide an authorization email from the customer’s email address on file with CozyPal. You can also submit a request on behalf of a California consumer under the California Consumer Privacy Act (CCPA), but you must provide the following documents: (1) A written authorization signed by the consumer authorizing you to exercise CCPA rights regarding their personal information on their behalf; or (2) Information acceptable to CozyPal used to verify the consumer’s identity. CozyPal will verify the identity and authorization directly with the consumer. If the agent fails to submit proof that they have obtained the consumer’s authorization, CozyPal may deny their request.

4.California users can apply via email to export your personal data in a structured, commonly used format. CozyPal will complete the export and provide it to you within 10 business days without charging any fees.

5.Right to opt-out of sale (limited to users in California): You have the right to refuse CozyPal selling your personal information. CozyPal has never sold user personal information and will not sell it without your explicit consent.

6.To submit a privacy request, you can send an email to cozypal@cozypal.chat. CozyPal may need you to verify your identity before exercising these rights. If you submit a request on behalf of a user, CozyPal requires an authorization letter signed by that user. If you disagree with CozyPal's response, please reply by email explaining your reasons and what you believe is missing or incorrect.

7. International Information Transfer

Given the international nature of CozyPal's business, CozyPal may need to transfer your information to its various affiliates to achieve the purposes described in this policy. Therefore, CozyPal may transfer your information to other countries/regions where the laws and data protection compliance requirements may differ from those in your country/region. If CozyPal transfers your personal information to any of the aforementioned third parties, and that third party processes the information in a manner inconsistent with data protection principles, CozyPal will bear responsibility under data protection principles unless CozyPal can prove it is not responsible for the event causing the damage.

CozyPal is committed to closely monitoring the latest developments in data privacy laws and regulations; any updates will be reflected in this Privacy Policy, and the legality of the transfer will be guaranteed through compliance methods such as standard contractual clauses and binding corporate rules.

If you are a European resident and have any complaints, concerns, or questions about CozyPal's privacy protection measures, please contact us via email at cozypal@cozypal.chat.

VI. Complaint Mechanism

In order to comply with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF), CozyPal commits to resolve all complaints related to its collection and use of your personal information under the Data Privacy Framework Principles. Individuals in the EU, the UK, and Switzerland with inquiries or complaints regarding CozyPal's handling of personal data received in reliance on the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF should first contact CozyPal at the email address cozypal@cozypal.chat.

Under specific circumstances, if your complaint cannot be resolved through any other means, you may choose binding arbitration.

VII. Contact Us

We reserve the right to change or modify this Privacy Policy at our sole discretion. You are responsible for periodically reviewing this page for updates, and CozyPal welcomes your comments on our Privacy Policy. If you have any questions or suggestions regarding our Privacy Policy, please contact us via email at cozypal@cozypal.chat.