Please read this privacy policy carefully before using Cozypal.
As a comprehensive social networking platform, the CozyPal App allows users to share content, experience AI companionship, express emotions, showcase their true selves, and build meaningful connections with others. All these activities involve the sharing of personal data, and at CozyPal, we are committed to protecting your privacy. This CozyPal Privacy Policy (hereinafter referred to as the "Policy") explains all privacy-related matters you may encounter when using our application (hereinafter referred to as the "App") and the services provided through it (collectively referred to as the "Services"). This Policy is an integral part of the "CozyPal" Service Agreement for Silver Hair Social App (hereinafter referred to as the "Terms") and is incorporated into the Terms by reference. Please read this Policy carefully. If you have any questions, please contact us via hello@cozypal.chat. If you have questions about how to exercise your rights, you may also contact us via hello@cozypal.chat.
This Privacy Policy explains what personal data we collect and how we process such personal data when you use our mobile App and the Services provided through it. By using our Services/App, you represent and warrant that: (i) you have read, understood, and agreed to this Privacy Policy; (ii) you are at least 18 years of age. If you do not agree to this Policy or cannot make such representations and warranties, you shall not use the App/Services. In such cases, you must: (a) delete your account and contact us to request the deletion of your data; (b) cancel all subscriptions through Apple (if you use an iOS system), Google (if you use an Android system), any other app stores that may be available from time to time, or the functions we provide.
CozyPal or certain services you use to interact with the Services may have their own privacy rules (third-party privacy policies). Therefore, if your personal data is processed by such services, such processing shall be governed by the third-party privacy policies rather than this Policy. Your "personal data" or "data" for short refers to any information related to you, or any information that can directly or indirectly identify you as an individual.
1.1 Although we make every effort, we cannot control how other users or third-party services use your data. When using CozyPal, you should assume that all content you post, share, or send on the App may be publicly viewed and accessed by CozyPal users and individuals outside the App. We encourage you to exercise caution when disclosing your data, and therefore, we urge you to follow the following privacy recommendations:
1.2 If your CozyPal profile and the information you provide contain sensitive data (such as religious affiliation, sexual orientation, health status, political views, any addictive behaviors, social security numbers, precise geolocation information, or ethnicity), we recommend that you use CozyPal "Interest Tags" to identify your specific preferences, rather than sharing some of your data in the text description of your profile. We believe this is a safer and more beneficial option, as you can modify or hide them at any time. At the same time, the "CozyPal Interest Tags" can also help you better connect with individuals who may share similar views and are more likely to reach out to you.
1.3 CozyPal allows you to share your personal information, including your precise location and information that may be considered "sensitive" or "special category" in certain jurisdictions, such as religion, political views, and philosophical beliefs. CozyPal will only collect such information with your explicit consent. If you do not explicitly consent to the processing of such sensitive data, we will not display tags related to religion, political views, or philosophical beliefs for you to choose from. However, you always have the right to request the deletion of your sensitive data or other data by removing the relevant tags in your profile settings, restricting certain users’ access to your profile (in which case the blocked users will not be able to see your data), or contacting hello@cozypal.chat
1.4 CozyPal also collects your location information to determine your distance from other users ("Distance Information"). The CozyPal App is designed to allow users to share Distance Information. If you choose to display your relative distance, your Distance Information will be shown on your profile and in the search results of these users. Please note that if you choose not to allow CozyPal to access your location information, certain functions of the CozyPal App may not work properly.
If you have granted CozyPal permission to access your location but wish to disable this function, you can do so in "My Page - Privacy Settings".
2.1 Reasons for Updates
We may modify this Policy from time to time based on new legislative developments or advancements and the broader data protection landscape. Therefore, please review this page regularly to ensure that you are always informed of any changes.
2.2 Notification of Updates
If we decide to make any material changes to this Agreement, we will notify you via email (sent to the address associated with your profile) or by posting a notice within the CozyPal Services before the changes take effect.
3.1 Information about who processes your data and with whom we may share your data is considered one of the most important points you should be aware of, so we have placed this section at the beginning of this Policy. In this section, we also explain which third-party sources we may use to receive your data.
3.2 Roles and Definitions
First, you should understand the concepts of 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 refers to an individual who has access to data in accordance with their rights or obligations.
3.3 Data Processors
In processing your data, we 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 App |
| Type | Audit and Photo Verification Tools |
|---|---|
| Collected Data | Photos |
| Purpose | Content auditing and assisting with user verification |
3.4 Software Development Kits (SDKs)
In addition to the above data processors, 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 App of another service, allowing the App to run on the specific platform of the SDK owner. Please find the following information about them:
| SDK Name | Provider | Processor’s Privacy Policy | Data That May Be Collected by the SDK | Purpose for Which We Use the Data |
|---|---|---|---|---|
| Sign in with Apple | Apple Inc. | https://www.apple.com/legal/privacy/en-ww/ | User-selected name and email address (can be hidden), device identifier, authorization status. | To provide users with the option to quickly and securely log in to this App using their Apple ID. |
| Google Sign-In | Google LLC | Google Privacy & Terms | Public profile information (e.g., name, avatar), email address, unique user identifier. | To provide users with the option to quickly and securely log in to this App using their Google account. |
| Agora Chat UIKit | https://agora.io/, Inc. | https://www.agora.io/en/privacy-policy/ | Chat message content, sender/receiver information, timestamps, device information, network status. | To provide real-time messaging services for core features (one-on-one chat, group chat). |
| In-App Purchase | Apple Inc. / Google LLC | https://www.apple.com/legal/privacy/en-ww/ / Google Privacy & Terms | Product identifier, transaction token, device information (for fraud prevention and transaction completion). | To process payments for users' purchases of virtual goods or premium services within the App. |
| Share_plus | Flutter Community | https://github.com/fluttercommunity/plus_plugins/tree/main/packages/share_plus/share_plus | Typically does not directly collect data. It invokes the system sharing interface; data is processed by the user-selected target application. | To allow users to share content from within the App (e.g., profiles, interesting conversation summaries) to other social platforms or applications. |
| Image_picker | Flutter Team | https://github.com/flutter/packages/tree/main/packages/image_picker | Access to device photo album or camera permissions. The SDK itself may not transmit data to external servers, but permission declaration is required. | To allow users to select photos/videos from their device album or capture them directly, for setting avatars, sending media in chats, or using the dietary logging feature. |
| Audioplayers & Video_player | Flutter Community / Flutter Team | Typically act as local players and do not actively collect data. However, the underlying platforms (iOS/Android) they rely on may involve data. | Device storage access permissions (to read media files), network permissions (to play online audio/video). | To play sound effects within the App, audio attachments in messages, and sent or received video messages. |
3.5 Additional Data Processors
If necessary, our Services may also involve other service providers, contractors, and third-party services, and we may share data with them. This helps us operate, provide, improve, integrate, customize, support, and promote our Services. We share data, particularly for the purposes described in this document. The types of service providers with whom we may share information may include: cloud storage providers, data analysis providers, measurement partners, marketing partners, payment processors, communication service providers, etc.
3.6 Sharing Consumer Information with App Store or Google Play
By registering on our CozyPal App, you agree that we may share your information (UUID of your in-app user account, your consumption status, the duration of your use of the App, platform type, and the amount you paid within the App) with the Google Play to help inform and improve the payment process. You may withdraw your consent at any time by contacting us via hello@cozypal.chat.
3.7 Audits
We have appointed a Data Protection Officer to monitor and review accounts (including names and any other information uploaded to user profiles). If a user’s profile fails to meet certain standards, indicating that the user may have violated the Terms of Use, the user’s access rights will be restricted and/or blocked. Affected users may contact CozyPal to object to this decision.
3.8 Third Parties - Access to Data by Other Users and Social Media
Some of your data is public; this means other CozyPal users may have access to your public data. Please carefully read Section 1 and follow our privacy recommendations to avoid accidental or improper disclosure of your data. Meanwhile, as stated in Sections 1.1(f)-(i), CozyPal users may choose to log in to the App using Apple or Google email authentication. If you do so, you authorize us (and in some cases, other users) to access certain information stored in your external account, including information you provide through these social media platforms, your friend list, current location, and mutual friends you have with other CozyPal users. To this end, please note the following:
3.9 Please note that we collect personal data directly from you, and we may also obtain some of your personal data from third parties. For example:
3.10 Disclosure of Data to Third Parties
CozyPal is a platform free from all forms of abuse, violence, and infringement of third-party rights. We have designed CozyPal to be a safe haven where people can be themselves and express their emotions. We make every effort to protect our most valuable asset - the sense of security of our users. Therefore, we may disclose your data to third parties in the following circumstances:
4.1 Age Restriction
We restrict the use of the Services to individuals who are at least 18 years of age (or the legal age of majority in their place of residence), and we will not intentionally collect personal information from anyone under the age of 18.
4.2 Notify Us
If we become aware that we have collected personal information from any individual under the age of 18 (or the legal age of majority in their place of residence), we will process such 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 if you believe a user is a minor, please contact us via email at hello@cozypal.chat or report the relevant profile through the appropriate function in the App.
4.3 Our Measures
If we discover that an individual under the age of 18 has registered with CozyPal and provided us with incorrect personal information, we will take measures to terminate the individual’s registration and delete all relevant registration data from CozyPal.
5.1 This section explains what data we collect (in addition to the data we collect as specified in Section 3.4), the sources from which we obtain your data, the purposes for which the data is used, and the legal basis for our processing of your data. In addition, we will also collect some of your privacy data that you share.
5.2 If you are a resident of the European Union, you can find information about your personal data that falls into special categories (such as racial origin, political opinions, religious or philosophical beliefs) which we may collect in accordance with the GDPR. Such data will only be collected if you choose to provide it and give your explicit consent (as stated in Article 9.2(a) of the GDPR).
5.3 For users who are residents of California, you can find more information about the categories of personal information and the collection of sensitive personal information in Sections 9.1-9.2 of this Agreement.
5.4 Purposes of Data Processing, Collected Personal Data, Sources, and Legal Basis
| Purpose | Personal Data Collected | Source | Legal Basis |
|---|---|---|---|
| Ensure the proper operation of the website and provide you with access | IP address; cookie identifiers (as set out in our Cookie Policy); user agent (CCPA Categories A and F) | We obtain this information automatically from your device | Performance of the service agreement entered into with you |
| Respond to requests you submit through the website (or directly by email) | Name; email address; IP address; your messages, including any data you choose to share with us (CCPA Categories A, B and H) | We receive this data from you | Performance of the service agreement with you or obtaining your consent (when you initiate communication by email) |
| Allow you to create a CozyPal profile | Name or nickname; date of birth (age); email address; phone number (depending on the registration method); your gender; photos; your description (CCPA Categories A, B, C, F and H) | We receive this data from you, and (for location) we obtain it from your device | Performance of the service agreement entered into with you |
| Provide you with a better communication and connection experience | Optional data, such as CozyPal tags: your interests, your preferences; your religious or political beliefs; photos; your education; marital status (CCPA Categories A, B, C, G, H, I and J) | We receive this data from you | Performance of the service agreement entered into with you |
| Display “nearby” location information to you and other App users | Wi‑Fi access points and location data when using the App (CCPA Category G) | You provide us with this information | Performance of the service agreement with you or obtaining your consent |
| Give you the opportunity to share content and opinions | Your photos; images you upload; text; videos; comments; data in your groups (CCPA Category F) | We receive this data directly from you (when you share it with us) or indirectly (when you generate data by using the App) | Performance of the service agreement entered into with you |
| Enable the video call feature | Video call usage data; images and videos (CCPA Categories F and H) | We obtain this data indirectly from you (when you generate data by using the App) | Performance of the service agreement entered into with you |
| Handle complaints made against you | Your profile data; shared content data; content of messages sent; other information we may obtain (CCPA Categories A, B, D, F, G and I) | We obtain this data from third parties or indirectly from you (when you generate data by using the App) | Legitimate interests or legal obligations |
| Verify your CozyPal profile/your identity/age; prevent, detect and combat fraud or other illegal or unauthorized activities; send text messages or emails with verification codes | Your photos; phone number; email address; any data we hold about you, depending on the issue we are handling (CCPA Categories A, D, F, G and I) | We may obtain data from you, third parties, or collect it automatically from your device | Legitimate interests or legal obligations |
| Ensure compliance with our policies and laws; exercise our rights; assist legal protection agencies and law enforcement | Any data we hold about you, depending on the issue we are handling (CCPA Categories A, B, D, F, G and I) | We may obtain data from you, third parties, or collect it automatically from your device | Legitimate interests or legal obligations |
| Provide you with paid services | Purchase history; payment details (CCPA Categories B and D) | You provide us with this information | Performance of the service agreement entered into with you and our legitimate interests |
| Implement anti-fraud and anti-spam procedures | Name; email address; phone number; IP address and IP session data; payments received; payment type; user ID; location | You provide this information, and we also collect it automatically from your device (IP address and IP session data, user agent ID, location, user ID) | Legitimate interests or legal obligations |
| Contact you for feedback, determine whether you are willing to participate in marketing activities, and send information about the Services (direct marketing) | Name; email address; user ID; data you disclose to us (CCPA Categories A and B) | You provide this information directly, and we collect it automatically from your device (user ID) | Legitimate interests or consent |
| Help you connect with other users and allow you to create a CozyPal profile | Race; political opinions; religious beliefs | You provide this information directly | Your explicit consent |
| Communicate with you about your activities on our Services (e.g., push notifications at specific times of day) | Push notifications; system type and device preferences; your device type | We collect this automatically from your device | Your explicit consent |
5.5 Legal Basis
The legal basis refers to the reasons for our processing of your data as specified in the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the California Privacy Rights Act (CPRA). We rely on the following legal bases:
5.6 You hereby confirm and agree that when you link your CozyPal profile to other services, and when we receive inquiries, court orders, subpoenas, claims, etc., we may receive your personal data from any third parties (other users, any official institutions, third-party providers, etc.).
5.7 We may from time to time launch surveys/feedback for research purposes and may contact you to determine if you are willing to participate. We may also contact you to determine if you are willing to participate in marketing activities. Such activities are optional. If you do not wish to receive notifications about participating in surveys or marketing activities, please contact us via hello@cozypal.chat or the appropriate in-app function. If you neither wish to contact us nor participate in our activities, please ignore our messages.
5.8 Behavioral Advertising
Since we rely on your consent to display personalized advertisements to you, you have the right to withdraw your consent at any time and request that we stop serving you personalized advertisements. Please contact us via email at hello@cozypal.chat to withdraw your consent.
5.9 Push Notifications
We use push notifications to keep you updated on your activities on our Services. These notifications may include reminders, incentive prompts to encourage participation, or other relevant information. For example, you may receive notifications about new messages, new replies, or new matches. To stop receiving push notifications (opt-out), you can adjust the settings on your device.
5.10 Purchase Information from Third-Party Payment Processors
We use a variety of third-party payment processors, including the App Store or Google Play. When you choose to make a purchase, you will submit personal information to our third-party payment processors, such as your name, payment card information, billing information, address, phone number, and email address. CozyPal does not directly process payment card information; however, our third-party payment processors may provide us with certain information (e.g., your name, address, partial payment card number, and email address).
6.1 Data Retention
Your data will be stored during your use of the Services until the termination of your use (or as agreed between you and CozyPal), which means the deletion, blocking, or suspension of your account on the mobile App and the restriction of your further use of the mobile App; we will terminate the processing of your personal information unless applicable laws specify a special retention period for such data storage at that time. We may also retain records to prevent fraud and ensure security, such as when a user is banned for violating our Terms or abusing our Services. Please note that the temporary deactivation, disabling, or "freezing" of an App account does not constitute account deletion.
6.2 Exceptions
When your profile is terminated (your account is deleted) or you have been inactive for two consecutive years, we will delete or anonymize your information, including the sensitive information listed for California residents. Special rules may apply in the following circumstances:
6.3 Deletion Terms
All your data will be completely deleted (or anonymized) within 7 calendar days after the deletion of your CozyPal profile, except in the following cases:
6.4 Remaining Information
After your account (and your data) is deleted from the Services, if your data has been previously shared with others or copied or stored by other users or other third parties, copies of your data may still be viewed. We cannot control this situation and assume no responsibility for it. If you authorize third-party Apps or websites to access your data, they may retain such information to the extent permitted by their privacy policies.
6.5 Removed and deleted data may be stored in backup form for up to 30 days, but no one else will have access to it during this period. We set these backup data as "unusable". After the expiration of this period, the data will be permanently deleted.
6.6 You always have the right to restrict our processing of your data by sending us a request for data deletion or a notice prohibiting the processing of your data. Please note:
6.7 Enforcement of CozyPal Usage Prohibition
If your profile is blocked, banned, or otherwise deactivated for violating applicable laws or the provisions of the Terms of Use or this Policy, you will be prohibited from creating new profiles and using the Services again. Therefore, we will continue to process the data listed in Section 6.3(c) of these Terms ("Technical Data") to prevent you from registering again and to prevent potential violations. Please note:
6.8 Server Location
Our servers are located in the United States, so your data may be processed and hosted outside the European Union. We hereby inform you that we use servers in the United States to collect and process data of users from other countries and regions. If you are located outside the United States, your information will be collected in your country/region and then transmitted to the United States - or other countries/regions where we (or our affiliates or service providers) operate.
6.9 Cross-Border Data Transfers
The information sharing listed in this document involves cross-border data transfers to the United States and other jurisdictions that may have different data processing laws. If we transfer personal data collected within the European Economic Area to a country with an insufficient level of data protection, we will use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (or any updated version of the contractual clauses issued by the data protection authority, if any), or (ii) Adequacy Decisions of the European Commission regarding certain countries. We take measures to ensure that the recipients are bound by the EU Standard Contractual Clauses and other safeguards to protect your personal data. You may request a copy of these clauses. In some cases, courts, law enforcement agencies, regulatory authorities, or security agencies in these countries may have the right to access your personal information.
Cookie Policy: We use Cookies and other tracking technologies to enhance your user experience and obtain data on website usage. This data enables us to develop and optimize the website and make your use of the Services more convenient. Please read the Cookie Policy for more information.
8.1 As a data subject, you have the following rights:
8.2 We will provide information on actions taken in response to requests related to your above rights within a maximum of one month after receiving the request. This period may be extended by two months if there is a large number of requests. We will notify you of any such extension within one month of receiving the request and explain the reason for the extension.
This section applies only to users in California. This section also provides additional details on how we process the personal data of California users and the rights users have under the California Consumer Privacy Act of 2018, the California Civil Code (Sections 1798.100-1798.199), the California Privacy Rights Act, and their implementing regulations (collectively referred to as the "CPPA").
9.1 Categories of Personal Data
For users who are residents of California, you can find the categories of personal information collected by CozyPal, as well as the business purposes and sources for collecting your personal information, in Section 5.4 of this Agreement. You can also find the following from the statutory list specified in the CCPA:
9.2 Sensitive Personal Information
In addition to the collection of personal data listed in Section 5.4, you can find the categories of your sensitive personal information and the business purposes for collecting such information in the CPPA.
| Category of Collected Sensitive Information | Purpose |
|---|---|
| Race, political opinions, religious beliefs | Helping you connect with other users and allowing you to create a CozyPal profile |
| Content of emails and text messages | Helping you connect with other users. When you send messages to other users (which may include content such as photos, videos, emojis, replies, etc.), we may collect personal information that includes the content of the messages. If you send a message, you are providing your personal data to the users who view your message. Do not send or share content that you do not want others to save or share. We store the content of messages on our servers in accordance with the retention rules described in this document. |
We only collect personal information such as your race, political opinions, and religious beliefs if you choose to display them by clicking on the "Interest Tags". Please note that only the approximate geographic location you share and personal information related to race or ethnicity, religion, or religious beliefs may be publicly viewed and accessed by users and non-users of this App.
9.3 Sale/Sharing of Your Personal Information
The definition of "sale" in the CPPA is very broad and covers many common commercial activities, even if personal information is not exchanged for monetary compensation. CozyPal does not sell personal information for monetary consideration; however, we may be deemed to "sell" or "share" certain personal information with third parties in situations that constitute "interest-based advertising" or "cross-context behavioral advertising" under the CPPA. That is, CozyPal may share your personal information with third parties to help provide you with personalized content or advertisements that may be more relevant to your interests.
In the 12 months prior to the effective date of this Privacy Policy, the third parties, service providers, and other processors with whom we may have shared or disclosed specific personal information are listed in Sections 3.3-3.10 of this Agreement. We disclose your personal information, including sensitive information, to the service providers and contractors listed in Sections 3.3-3.10 of this Agreement for commercial purposes, but this is not defined as "sale" or "sharing" under the CPPA. CozyPal may share certain personal information (advertising identifiers; localization data; IP addresses, referrers; type of Internet connection, app version, device model, manufacturer, operating system, operating system version, screen size (height, width), screen resolution, mobile network status; user ID; channel mode; SDK version; network type; app ID; email address; localization data; approximate geographic location) with our advertising/marketing partners in accordance with the provisions of the CPPA. These third parties may also collect information directly from you through tracking technologies such as Cookies or SDKs. You may request to opt out of the sale/sharing of your personal information.
9.4 Your Rights
For users who are residents of California, in addition to the rights listed in Section 8.1 above, you also have the following rights:
9.4.1 Right to know what personal information is being collected and what personal information is being sold or shared. You have the right to request the following information about data twice within 12 months:
9.4.2 Right to delete your personal information or correct inaccurate personal information. You may request CozyPal to delete any personal information about you collected by CozyPal. You also have the right to request CozyPal to correct inaccurate personal information about you based on the nature of the personal information and the purpose of processing the personal information.
How to Submit a Request: To submit a request for information disclosure, deletion, or correction, please contact us via email at hello@cozypal.chat.
9.4.3 Right to opt out of the sale or sharing of personal information. You may instruct CozyPal not to sell or share your personal information, and CozyPal will stop sharing your personal information with third parties.
9.4.4 Right to restrict the use of your sensitive personal information. You may instruct that the collection of sensitive personal information as described in Section 9.2 of these Terms be restricted to use within the scope necessary for using CozyPal Services.
To submit a request to opt out of the sale or sharing of your personal information or to restrict the use of your sensitive information, please contact us via email at hello@cozypal.chat.
9.5 If you choose to exercise any privacy rights specified in the CPPA, you have the right not to be discriminated against by CozyPal.
9.6 To protect your privacy and maintain security, we will take measures to verify your identity before granting you access to data or fulfilling your request. If a consumer's request is clearly unfounded or excessive, particularly due to its repetitiveness, we may refuse to fulfill the request and notify you of the reason for the refusal.
9.7 You may also authorize an agent to submit a request on your behalf. If you do so, we may require you to provide evidence that you have provided the agent with a valid power of attorney or other written authorization to submit the request on your behalf, and we may also take measures to verify your identity. Due to the sensitivity of your data, we reserve the right to refuse any request submitted by a third party regarding your data at any time.
Pursuant to the Virginia Consumer Data Protection Act (VCDPA) and the Texas Data Privacy and Security Act (TDPSA), consumers residing in Virginia or Texas respectively have certain additional rights regarding their personal information. This section applies to you if you are a resident of Virginia or Texas.
10.1 Our Collection and Use of Personal Information
You can find the categories of personal information collected by CozyPal, as well as the purposes and sources for collecting your personal information, in Section 5.4 of this Agreement.
10.2 Processing of Your Sensitive Data
We process your sensitive data, including race, political opinions, and religious beliefs. We may seek your consent to process these categories of sensitive information and disclose them to other users. However, you always have the right to request us to stop displaying this data to others by removing the relevant tags in your profile settings.
10.3 Exercising Your Consumer Rights
You have the right to request (1) confirmation of whether the data processor is processing the consumer's personal data and access to such personal data; (2) correction of inaccuracies in the consumer's personal data, taking into account the nature of the personal data and the purpose of processing the consumer's personal data; (3) deletion of personal data about the consumer that was provided or obtained by the consumer; (4) obtaining a copy of the consumer's personal data previously provided by the consumer to the data processor in a portable format that is easy to use to the extent technically feasible, allowing the consumer to transmit the data to another controller without hindrance if the processing is conducted through automated means; (5) opting out of the processing of personal data for targeted advertising purposes.
You may exercise your rights by contacting us via hello@cozypal.chat. We will not discriminate against you if you exercise the rights granted to you under the VCDPA or TDPSA. If you wish to appeal CozyPal's refusal to process your request, you may contact us via hello@cozypal.chat. CozyPal will notify you in writing within 60 days of receiving the appeal of any actions taken or not taken in response to the appeal.
10.4 Sale of Personal Information
We do not sell your personal information. We do not engage in monetary transactions of your personal data with third parties, so there is no need to opt out. However, we process your personal information for targeted advertising purposes in accordance with the provisions of the VCDPA. We will display advertisements to you based on personal data obtained from unrelated websites or online apps. You may contact us via hello@cozypal.chat to opt out of the processing of your personal data for targeted advertising purposes.
11. Data Subject Access and Deletion Requests
Methods of Submitting a Request
If you are a user in the European Union, you may contact us via hello@cozypal.chat to exercise your right to access or delete your data. If you are a California consumer, you may exercise your privacy rights in accordance with Section 9. For consumers in Virginia and Texas, please refer to Section 10.
12.1 This Service may contain links to websites operated and maintained by third parties, and we have no control over these third-party websites. The privacy policies of such linked websites may differ from this Policy. You access such linked websites at your own risk. Similarly, this Service may also be accessed and used by third-party websites that we cannot control. We have no control over the privacy policies of such third-party websites, and you access such third-party websites at your own risk.
13.1 We adopt commercially reasonable protection measures to ensure the security of your data. At CozyPal, we prioritize the privacy and security of your personal information through robust measures and continuous improvements. Our security settings are designed to protect the security of your data and include the following key components:
13.3 We regularly monitor our systems for potential vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our technical and organizational security measures.
13.4 To the maximum extent permitted by applicable law, we explicitly disclaim any express or implied representations or warranties regarding any security breaches, damage to your device, or loss or unauthorized use of your registration information or other data.
14.1 We welcome your correspondence. If you have any questions about this Policy, please contact us via hello@cozypal.chat.
Last Updated: December 2025