Privacy Policy
This Privacy Policy (the "Policy") serves as an essential component of the AZUR APPS Terms of Service (the "Agreement"). Unless explicitly defined otherwise within this document, all capitalized terms shall hold the meanings ascribed to them in the Agreement.
AZUR APPS FZ LLC ("we," "us," or the "Company") is dedicated to safeguarding your privacy. We treat your personal data (the "Data") with the utmost seriousness. We will only collect, process, and use your Data to manage your account and deliver our services upon securing your consent. This Policy details the types of Data we collect, the timing and location of collection, our reasons for doing so, the legal grounds for processing, how the Data is utilized, the circumstances under which we might share it with third parties, your rights regarding your information, and our security measures. Should you have any inquiries, please reach out to us at dpo@azurapps.com.
By accessing or using the Service, you consent to the collection and processing of your Data as governed by this Policy.
1. Introduction
1.1. Under the terms of this Policy, we may utilize your personal information to:
- Verify and authenticate User identity;
- Deliver the functionality of our Application to the User;
- Notify the User regarding updates, news, and promotional offers;
- Secure, sustain, and enhance the Application;
- Defend the legal rights and interests of both the Company and our Users.
2. Your Personal Data and Our Usage
2.1. Registration & Login Data. This may include your full name, Account Photo, username/nickname, User ID, email address, date of birth, gender, city, region, country, and credentials from social media linked accounts. You are the direct source of this data. This information is mandatory for granting you access to the Service. The legal basis for this processing is your consent, the performance of the contract between us, and/or steps taken at your request prior to entering into a contract.
2.2. Automatically Collected Data. When you use the Service, your software automatically transmits certain information, including but not limited to: your IP address, cookie file content, data provided by your browser or other access software, the time/date of access, requested URLs, digital wallet IDs, and CSP names. If you purchase products or services, we may collect your name, partial credit card number, and other payment details. The legal basis for this is your consent and the necessity to perform the contract. We employ all commercially reasonable measures to ensure your payment details are kept confidential, utilizing only third-party billing services that are GDPR-compliant and use industry-standard encryption to protect your financial data from unauthorized access.
2.3. Usage & Analytics Data. This refers to information about how you interact with the Application. This is generally non-personal, identifying information provided by servers and browsers (e.g., via Google Analytics), such as browser type, language settings, referring sites, and visit timestamps. We also track how you use the App (e.g., search queries) and your approximate location. Usage data generally falls into two categories:
- Business Analytics: Data collected for behavioral statistics, marketing, and business intelligence (e.g., traffic data via Google Analytics).
- Technical Info: Data gathered for fraud prevention, security monitoring, and error tracking. The legal basis for this processing is our legitimate interest (and that of third parties) to monitor Service quality, improve the Application, prevent fraud/crime, and ensure security.
2.4. Communications Data. This encompasses any information stored in or related to messages you send to us or generate within the Application. It includes:
- Support Correspondence: All emails, tickets, and communications with Customer Support or during dispute resolution.
- User Interactions: Messages, attachments, and data generated during communication with other Users. This data may include names, nicknames, IPs, avatars, audio/video files, and for manual verification: photos of the User, their ID documents, and utility bills. Additionally, our system may randomly capture screenshots of User chats. We process this to communicate with you, resolve disputes, prevent misconduct/abuse, and improve service quality. Our legitimate interests—specifically the proper administration of the Service and prevention of prohibited behavior—serve as the legal basis.
2.5. Notification Data. This consists of information you provide to receive SMS or email alerts/newsletters (e.g., email, name, phone number). We process this to deliver requested notifications. Your consent is the legal basis. You may unsubscribe at any time via the link in emails, Profile Settings, or by contacting us.
2.6. Legal & Safety Compliance. We may use your info for regulatory compliance, safety audits, litigation, or pre-litigation purposes. You consent to the use of your data as evidence of your App usage in the event of a dispute. The legal basis is our legitimate interest in asserting and defending our rights, your rights, and the rights of others.
2.7. Vital Interests. Beyond the specific purposes listed, we may process your data when necessary to protect your vital interests or those of another natural person (e.g., in life-threatening situations). The Company does not verify the authenticity of provided data; we rely on you to provide accurate information and keep it current.
2.8. Biometric Data. To adhere to legal standards and secure our platform, we verify that users meet the minimum age requirement. We utilize a Third-Party Verification Provider for this service. During verification, the User voluntarily and with explicit consent submits a video selfie. This video is analyzed to create facial geometry data ("biometric information") solely for:
- Estimating and confirming age;
- Liveness detection (to prevent spoofing or bots). We do not receive or store the original video, face snapshots, or biometric templates. We only receive a "Pass" or "Fail" status from the provider to grant or deny access.
2.9. ID Documentation. If automated biometric verification fails, the User has the Right to Appeal by submitting a valid Identity Document (ID) to Support for manual review. We process this strictly to confirm age. The document is permanently deleted immediately after review (within 24 hours). We retain only the verification status, not the document copies.
3. Publicly Displayed Information
3.1. Users often voluntarily disclose personal or sensitive information while using the App (e.g., in optional profile fields, public chats, or by switching private chats to public). Any information you post in public sections of the Application is considered public, regardless of its sensitive nature. By posting such information, you acknowledge that you waive privacy rights regarding that specific content.
3.2. Please be aware: if you share identifiable info via public functions, it can be read, collected, and used by third parties beyond our control, and may be indexed by search engines. We strongly urge you to exercise caution before sharing any sensitive personal details.
4. Data Transfer to Third Parties
4.1. Except as required by law, the Company commits not to sell, rent, or exchange User personal information with third parties without User consent. We may grant third-party access only if:
- The User has given explicit consent;
- The transfer is necessary to operate the Application (in such cases, we require the third party to maintain confidentiality).
4.2. We may utilize the following data processors:
- Firebase (Google): To analyze Website/App activity. Entities may include Google LLC (USA), Google Ireland Ltd, etc.
- Facebook Sync: To allow login via Facebook ID.
- Apple Sync: To allow login via Apple ID.
- Google Sync: To allow login via Google account.
- Amplitude: An analytics service (Amplitude Inc., USA) to understand User behavior (collects IDFA, device type, time zone).
- AppsFlyer: An analytics service (AppsFlyer Inc., USA) for marketing and feature optimization (collects IDFA, device specs).
- Third-Party Verification Service: Processes facial geometry for age assessment. Data is processed on their servers and deleted immediately after verification. The legal basis is your Explicit Consent.
4.3. For email campaigns and business intelligence, we use Google Analytics (Google LLC, USA). We supply your IP address and usage data to Google for these purposes.
4.4. Your data may also be processed by partners providing SDK (Software Development Kit) technology integrated into our App.
- Firebase Analytics SDK: Collects session duration, device models, OS, geography, in-app purchases, and updates. Purpose: Optimization and user support.
- Agora SDK (Agora Lab, Inc.): Collects device info, user ID, network quality, call duration, and audio/video resolution. Purpose: To enable and record streaming/video call features.
4.5. In addition to the above, we may disclose information:
- To legal counsel, auditors, and advisors for professional advice or dispute resolution;
- To fulfill contractual obligations or protect vital interests;
- To comply with laws or during a merger, acquisition, or asset sale (with notice to Users).
5. Links to Third-Party Sites
5.1. The Application may contain links to third-party websites. While we strive to ensure partners are compliant and lawful, we do not control these sites. They operate under their own privacy policies. We are not liable for their practices. Accessing them is at your own risk; please review their privacy notices.
6. Protection of Children
6.1. The Application is strictly for individuals 18 years of age or older. We do not knowingly collect data from minors. If a minor attempts to access the App, we take measures to block them. If you are a parent/guardian and suspect your child is using the App, please contact us. We may request ID proof before deleting data to prevent malicious account removal. Upon confirmation, data belonging to minors will be deleted expediently. You agree that ID info is accepted "AS IS" for age verification; we are not liable if a User provides misleading documents.
7. Illegal Activity & Law Enforcement
7.1. We reserve the right to investigate complaints or reported violations. We may take any action we deem appropriate, including reporting suspected illegal activity to law enforcement, regulators, or third parties. We may disclose any relevant information (profile, email, history, traffic data, IP) to such authorities.
8. International Data Transfers
8.1. Your information may be stored or processed globally. Some functions require sending data to third-party providers located outside your local jurisdiction (e.g., outside the EEA). All such providers are listed in Section 4. If data is transferred to a country without adequate data protection laws (as defined by GDPR), we ensure appropriate safeguards, such as standard contractual clauses, are in place.
9. Data Retention and Deletion
9.1. We process personal data only for as long as necessary to fulfill the intended purpose.
9.2. Users may request account deletion via the Service settings.
9.3. Post-deletion retention schedule:
- Identity Analytics Data: Deleted 30 days after account deletion.
- Public Profile: Hidden 30 days after account deletion.
- Communications: Deleted 30 days after account deletion.
- Random Screenshots: Overwritten continuously; retained for a maximum of 90 days (for safety/moderation).
- Login, Account, Technical & Trade Data: Deleted 90 days after account deletion.
9.4. In some cases, exact retention periods cannot be predefined. Data will be kept as long as essential for service provision, payment processing, support, or auditing/legal reasons.
9.5. Notwithstanding the above, we may retain data for a reasonable period if required by law or to protect vital interests.
10. Your Rights
10.1. You possess specific rights under data protection laws. Some are complex; for full details, please consult relevant laws and regulatory guidance.
10.2. Your primary rights include:
- Right to Access: You may confirm if we process your data and request a copy. The first copy is free; subsequent copies may incur a fee. Contact Support to exercise this.
- Right to Rectification: You may request correction of inaccurate data or completion of incomplete data.
- Right to Erasure: You may request the deletion of your personal information (subject to the retention periods in Section 9).
- Right to Object: You may object to processing based on your specific situation, provided there are no compelling legitimate grounds for us to continue processing (e.g., legal claims).
- Right to Restriction: You may ask us to suspend processing in specific cases (e.g., while contesting data accuracy).
- Right to Portability: If processing is based on consent and automated, you may request your data in a structured, machine-readable format (unless this affects others' rights).
- Right to Complain: If you believe we breached data protection laws, you may lodge a complaint with the supervisory authority in your place of residence, work, or the alleged breach location.
- Right to Withdraw Consent: You may withdraw consent at any time. This does not affect the lawfulness of processing that occurred prior to withdrawal.
10.3. If we have reasonable doubts about the identity of a requester, or for security reasons, we may request additional information to verify your identity before fulfilling these rights.
10.4. You can exercise these rights by contacting Customer Support. You may also exercise the "Right to Erasure" by using the delete account function in the App.
11. Contact Us
11.1. Customer Support Email: info@azurapps.com
11.2. If you have questions regarding this Privacy Policy, our data practices, or your rights, please contact our Support team.
11.3. The Data Controller is AZUR APPS FZ LLC.