# COMBOSATION APP - PRIVACY POLICY

**Last Updated: September 22, 2025**

## 1. INTRODUCTION

This Privacy Policy describes how Combosation ("we," "our," or "us") collects, uses, and shares your personal information when you use the Combosation messaging application ("App"). We are committed to protecting your privacy and being transparent about our data practices.

By using the App, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the App.

## 2. INFORMATION WE COLLECT

### 2.1 Information You Provide Directly

**Account Information:**

- Display name and username

- Email address

- Phone number (if provided)

- Profile pictures and photos

- Password (encrypted)

**Content and Communications:**

- Text messages you send and receive

- Images, photos, and media files you share

- Voice messages and audio content

- Group chat information and settings

- Search queries within the App

**Profile and Preferences:**

- Profile customization choices

- App settings and preferences

- Friend connections and contact lists

- Notification preferences

### 2.2 Information We Collect Automatically

**Usage Information:**

- Features you use and how you interact with the App

- Time, frequency, and duration of App usage

- Messages sent to our AI assistant "Combo"

- Search history within conversations

- App performance and crash data

**Device Information:**

- Device type, model, and operating system

- Unique device identifiers

- IP address and general location information

- App version and build information

- Network connection type and carrier information

**Log Data:**

- Access times and dates

- App errors and debugging information

- Feature usage analytics

- Performance metrics

### 2.3 Information from Third Parties

**Firebase/Google Services:**

- Authentication data

- Cloud storage metadata

- Analytics information

- Crash reporting data

**OpenAI Integration:**

- Content sent to our AI assistant for processing

- AI interaction metadata

## 3. HOW WE USE YOUR INFORMATION

### 3.1 To Provide Our Services

- **Account Management:** Create and maintain your user account

- **Messaging:** Enable real-time communication between users

- **AI Features:** Power Combo AI assistant responses

- **Synchronization:** Sync your data across multiple devices

- **Search:** Provide search functionality within your conversations

- **Friend Connections:** Help you connect with other users

### 3.2 To Improve Our Services

- **Analytics:** Understand how users interact with the App

- **Performance:** Monitor and improve App performance

- **Features:** Develop new features based on usage patterns

- **Security:** Detect and prevent abuse, spam, and security threats

- **Bug Fixes:** Identify and resolve technical issues

### 3.3 To Communicate with You

- **Service Updates:** Notify you about App updates and changes

- **Security Alerts:** Inform you about security-related issues

- **Support:** Respond to your questions and provide customer support

- **Policy Changes:** Notify you about changes to this Privacy Policy

### 3.4 Legal and Safety

- **Compliance:** Comply with applicable laws and regulations

- **Legal Processes:** Respond to legal requests and court orders

- **Safety:** Protect the rights, property, and safety of users

- **Terms Enforcement:** Enforce our Terms of Use

## 4. HOW WE SHARE YOUR INFORMATION

### 4.1 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

### 4.2 Service Providers

**OpenAI:**

- Message content sent to Combo for AI processing

- Conversation context for relevant responses

- Usage data for service improvement

**Firebase/Google:**

- User authentication and account management

- Message storage and synchronization

- App analytics and performance monitoring

- Push notifications

**Cloud Storage Providers:**

- Encrypted message and media storage

- Cross-device data synchronization

- Backup and recovery services

### 4.3 Legal Requirements

We may disclose your information if required by law or in response to:

- Valid legal processes (subpoenas, court orders)

- Government investigations

- Emergencies involving danger to persons

- Protection of our rights and property

### 4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

### 4.5 Aggregated Data

We may share anonymized, aggregated data that cannot identify individual users for:

- Research and analytics

- Industry reports

- Service improvement

## 5. DATA RETENTION

### 5.1 Account Data

We retain your account information for as long as your account is active or as needed to provide services.

### 5.2 Messages and Content

- **Active Conversations:** Stored until you delete them

- **Deleted Messages:** May remain in backups for up to 90 days

- **Media Files:** Stored for the duration of the conversation

- **AI Interactions:** Conversation context retained for service improvement

### 5.3 Log Data

Usage logs and analytics data are typically retained for 12-24 months for service improvement and security purposes.

### 5.4 Legal Hold

We may retain information longer if required by law or legal processes.

## 6. DATA SECURITY

### 6.1 Technical Safeguards

- **Encryption:** Data encrypted in transit and at rest

- **Access Controls:** Limited access to personal information

- **Secure Infrastructure:** Industry-standard security measures

- **Regular Audits:** Security assessments and monitoring

### 6.2 Organizational Safeguards

- **Employee Training:** Staff educated on privacy practices

- **Data Minimization:** Collect only necessary information

- **Regular Reviews:** Periodic privacy impact assessments

- **Incident Response:** Procedures for security breaches

### 6.3 Limitations

While we implement strong security measures, no system is 100% secure. We cannot guarantee absolute security of your information.

## 7. YOUR PRIVACY RIGHTS

### 7.1 Access and Control

- **Account Settings:** Modify your profile and preferences

- **Message Deletion:** Delete individual messages or conversations

- **Data Export:** Request a copy of your data

- **Account Deletion:** Delete your account and associated data

### 7.2 Communication Preferences

- **Notifications:** Control push notification settings

- **Marketing:** Opt out of promotional communications

- **Email Updates:** Manage email communication preferences

### 7.3 Regional Rights

Depending on your location, you may have additional rights under local privacy laws:

**European Union (GDPR):**

- Right to access your personal data

- Right to rectify inaccurate data

- Right to erasure ("right to be forgotten")

- Right to restrict processing

- Right to data portability

- Right to object to processing

**California (CCPA):**

- Right to know what personal information is collected

- Right to delete personal information

- Right to opt-out of sale of personal information

- Right to non-discrimination

## 8. CHILDREN'S PRIVACY

### 8.1 Age Restrictions

The App is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

### 8.2 Parental Consent

For users between 13 and 18, we recommend parental guidance and consent before using the App.

### 8.3 Discovery of Child Data

If we learn that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

## 9. INTERNATIONAL DATA TRANSFERS

### 9.1 Global Service

The App is available worldwide, and your information may be transferred to and processed in countries other than your residence.

### 9.2 Safeguards

When transferring data internationally, we ensure appropriate safeguards are in place, including:

- Standard contractual clauses

- Adequacy decisions by relevant authorities

- Other lawful transfer mechanisms

### 9.3 Data Localization

Some data may be stored locally in your region to comply with local laws and improve performance.

## 10. THIRD-PARTY SERVICES

### 10.1 Integration

The App integrates with third-party services that have their own privacy policies:

**OpenAI:**

- Privacy Policy: https://openai.com/privacy/

- Data Processing Agreement applies to Combo interactions

**Google/Firebase:**

- Privacy Policy: https://policies.google.com/privacy

- Covers authentication, storage, and analytics

**Apple/Google App Stores:**

- Respective privacy policies apply to app distribution and payments

### 10.2 Third-Party Links

The App may contain links to third-party websites or services. We are not responsible for their privacy practices.

## 11. COOKIES AND TRACKING

### 11.1 Local Storage

The App may store information locally on your device for:

- App preferences and settings

- Authentication tokens

- Cached content for performance

- Offline functionality

### 11.2 Analytics

We use analytics services to understand App usage and improve our services. These may include:

- Firebase Analytics

- Crash reporting services

- Performance monitoring tools

### 11.3 Opt-Out

You can control some analytics through your device settings or app preferences.

## 12. DATA BREACH NOTIFICATION

### 12.1 Our Response

In the event of a data breach that may affect your personal information, we will:

- Investigate the incident promptly

- Take steps to secure the affected systems

- Notify relevant authorities as required by law

- Inform affected users when appropriate

### 12.2 User Actions

If you suspect unauthorized access to your account:

- Change your password immediately

- Review your account activity

- Contact our support team

- Monitor for suspicious activity

## 13. PRIVACY BY DESIGN

### 13.1 Principles

We incorporate privacy considerations into our App development:

- **Data Minimization:** Collect only necessary information

- **Purpose Limitation:** Use data only for stated purposes

- **Transparency:** Clear communication about data practices

- **User Control:** Provide meaningful choices about data use

### 13.2 Regular Review

We regularly review and update our privacy practices to ensure they remain effective and compliant.

## 14. UPDATES TO THIS PRIVACY POLICY

### 14.1 Changes

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

### 14.2 Notification

We will notify you of material changes through:

- In-app notifications

- Email notifications

- Updates to this document with revision date

### 14.3 Continued Use

Your continued use of the App after changes become effective constitutes acceptance of the updated Privacy Policy.

## 15. CONTACT INFORMATION

### 15.1 Privacy Questions

For questions about this Privacy Policy or our privacy practices, contact us at:

**Privacy Officer:**

Email: privacy@combosation.com

Address: [Your Company Address]

### 15.2 Data Subject Requests

To exercise your privacy rights or make data subject requests:

**Email:** privacy@combosation.com

**Subject Line:** "Privacy Rights Request"

**Include:** Your name, account information, and specific request

### 15.3 General Support

For general support and questions:

**Email:** support@combosation.com

**App Support:** Available through the App settings

### 15.4 Response Time

We will respond to privacy-related inquiries within:

- 30 days for general inquiries

- 72 hours for urgent security matters

- As required by applicable privacy laws

## 16. LEGAL BASIS FOR PROCESSING (EU USERS)

For users in the European Union, we process your personal information based on:

- **Consent:** When you provide explicit consent

- **Contract:** To fulfill our Terms of Use agreement

- **Legitimate Interest:** For service improvement and security

- **Legal Obligation:** To comply with applicable laws

## 17. CALIFORNIA PRIVACY DISCLOSURES

### 17.1 Information Categories

In the past 12 months, we have collected the following categories of personal information:

- Identifiers (name, email, phone)

- Commercial information (usage patterns)

- Internet activity (app interactions)

- Geolocation data (if permitted)

- Audio/visual information (photos, voice messages)

### 17.2 Business Purposes

We use personal information for:

- Providing messaging services

- Customer support

- Security and fraud prevention

- Service improvement

- Legal compliance

### 17.3 Your Rights

California residents have the right to:

- Know what personal information is collected

- Delete personal information

- Opt-out of sale (we do not sell personal information)

- Non-discrimination for exercising rights

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**This Privacy Policy is effective as of the date listed above and applies to all users of the Combosation App. By using our App, you acknowledge that you have read and understood this Privacy Policy.**