Last updated: May 9, 2024
Welcome to Roulette.Chat (the “App” or “we” or “us”). We offer a website and a free app (“App”) that you can download onto your mobile phone to provide our services to you. This policy sets out the basis on which any personal data from you will be processed, collected, used, and disclosed by us when you access or use our website, applications, products, and content (collectively, the “Services”).
We are the controller of your personal data in the sense of the General Data Protection Regulation (“GDPR”) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding the Platform. As such, we are committed to protecting and respecting your privacy.
We are committed to safeguarding the privacy of our service users. This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data. Your use of our service manifests your consent to the transmission of personal data specified in this policy.
It goes without saying, we can’t help you develop meaningful connections without you providing some information about yourself, like basic profile details and the types of people you’d like to meet. Using our service also generates some information, such as when you logged in and how you used the service. We may also collect data from third parties, like when you access the service through an account you have on another platform (e.g., Google, Apple, or other) or when you upload information from your account on another platform to complete your profile.
Personal Data refers to any information that can identify an individual or is related to an identifiable individual. This includes, but is not limited to, names, email addresses, phone numbers, profile pictures, video recordings, chat histories, location data, IP addresses, and any other data that users provide or is generated through their interaction with the service. Personal Data encompasses both direct identifiers (e.g., name, contact information) and indirect identifiers (e.g., behavioral data, device information) that, when combined with other information, can uniquely identify a user.
When you create an account, you need to give us basic information for your account to be set up such as your nickname, gender, date of birth, and social media data used to create your account, depending on your choice.
Using the service generates data about your activity, including how you use it (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages, ads you interacted with) and how you interact with others (e.g., searching, matching, communicating, streaming, gifting, likes, battles). We may also receive data related to interactions you had with our ads on third-party websites or apps.
Using the service involves the collection of data from and about the device(s) you use to access our service, including hardware and software information such as IP address, device ID, type, version, information, language, timezone, performance, bandwidth; app settings and characteristics, carrier information, app crashes, advertising IDs, and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
When you contact us, you provide us with information that may be necessary to help address your inquiry. Other people may also submit queries or reports involving you. Finally, our moderation tools and teams can collect additional data as part of their investigations.
When you complete your profile, you can share additional details about yourself. Some of this data may be considered sensitive or special in certain countries, such as details about your gender. If you choose to provide this data, you consent to us using it as laid out in this Privacy Policy.
When you use our service, you may post photos, videos, audio, text, and other types of content, such as your chats with other members or when you livestream.
When you make a purchase, request a refund, or cash out, we keep the details of the transaction (e.g., what you purchased, the date of the transaction, and the price). The exact data depends on the payment method you choose. When you pay, request a refund, or cash-out directly with us (rather than through a platform such as iOS or Android), you provide your debit or credit card number or other financial info.
When you choose to share with us information about other people (for example, if you use the contact details of someone you know for a given feature or if you submit a query or report involving a member), we process this data on your behalf to complete your request.
We may process data about your use of our service (“usage data”). The usage data may include your IP address, geographical location (limited to country and state), browser type and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of our service. The legal basis for this processing is your consent in the form of use of our service as stated in Section 1, and our legitimate interests, namely monitoring and improving our service.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our service may generate the metadata associated with communications made using the service contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. We need this kind of data for the proper administration of our service and communications with users.
We may process information about your client application (web browser or mobile application) and its environment (operating system and hardware) used to access our service (“client data”). The client data may include your IP address, browser type and version, browser capabilities, operating system type and version, hardware setup, IMEI/ESN code, device manufacturer, serial number, and model name. We need this kind of data for the proper administration of our service.
We may process information that you send in text messages through our service (“message data”). The message data may be processed for the purposes of enabling such transfer and administering our service. We need this kind of data for the proper administration of our service, monitoring, and improving our service.
We may process information about your communication with other users in our service (“communication data”). The communication data may include client and usage data for both sides, the time and date of the communication, and its length. We need this kind of data for the proper administration of our service, monitoring, and improving our service.
We may process information about your ban (“ban data”) if you have been banned because of inappropriate behavior. The ban data may include different elements of usage data and client data necessary to block the user from using our service for a determined period, but also an image of the video frame obtained from a user’s video source. This image can be collected along with a complaint from another user (interlocutor) or when inappropriate behavior is detected by our system based on behavioral factors (how often interlocutors break off the connection, average duration of chat sessions, dubious message patterns, etc.). We need this kind of data for the proper administration of our service.
We may process complaint information (“complaint data”) if another user of our service complains about you. The complaint data may include an image of the video frame obtained from your video source. We need this kind of data for the proper administration of our service.
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our service (“transaction data”). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. We need this kind of data for the proper administration of our service.
We may process information that your browser sends whenever you visit our site (“log data”). The log data may include your IP address, browser type and version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, and other statistics. The log data collected does not include personally identifiable information. We need this kind of data for the proper administration of our service, statistical analysis, and understanding of user behavior.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We need this kind of data for the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
We may process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
The hosting facilities for our service are situated in Europe. Users of our service are located in multiple countries, including the European Economic Area. We have developed data practices designed to ensure information is appropriately protected, but we ask you to be aware of the privacy and data protection laws in the jurisdiction in which you reside. As otherwise stated in this policy, you acknowledge that the ultimate responsibility for the information you choose to share is yours.
You acknowledge that personal data that you submit for publication through our service may be available, via the Internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
The main reason we process your data is to provide our service to you and improve it over time. That includes connecting you with like-minded members, personalizing your experience, and just helping you make the most of our service. We also process your data to keep you and all of our members safe and secure while using our service. We take this responsibility very seriously and we’re always working to improve our systems and processes to help protect you.
We may process your registration data. Registration data may include: your full name, photo (your “avatar”), ID, username and email address, gender, date of birth, country, region, and city of residence as well as your social network account data. The source of the data is you. Registration data is required in order for you to be able to access and use the Service. The legal bases for this processing are consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process your usage data. Usage data is data about your use of the Service. Usage data is primarily non-personally-identifying information of the sort that web browsers, servers, and services like Google Analytics typically make available, such as the browser type, language preference, referring site, and the time of each visit. Other information that we might have access to includes how you use the Service (e.g. search queries), your approximate location, etc.
Usage data may include:
The legal basis for this processing is our legitimate interests and/or by third parties, namely to monitor the quality of the Service and improve the Service as well as to prevent, detect and investigate fraud, criminal activity, or other misuse of the Service and to prevent security issues.
We may process your communication data. Communication data is information contained in or relating to any communication that you send to us or generate through the use of our Service.
Communication data includes:
Communication data may include email address, username, avatar, IP address, full name, audio, and video files. Our system may also randomly take screenshots of your communications with other Users. The communication data may be processed for the purposes of communicating with you, record-keeping, in order to review and resolve disputes, prevent illegal and objectionable behavior, serve our customers better and improve our Service. The legal bases for this processing are our legitimate interests, namely the proper administration of our Service and business, prevention of illegal and/or immoral behaviour.
Some Users may elect to publicly post personally identifying or sensitive information about themselves in their normal use of our Service. This could occur through the use of optional profile fields, interactions in chats, or if a previously private interaction is made public. Information like that, which is voluntarily posted in publicly visible parts of our Service, is considered to be public, even if it would otherwise be considered to be personally identifying or sensitive. Voluntarily publicizing such information means that you lose any privacy rights you might normally have with regards to that information.
Our service may require a direct connection to be made between your computer and the other user’s computer. To do this, it is necessary to make your IP address available to the other user’s computer, although it is not shown to the other user by service’s interface. This is a necessary part of how any peer-to-peer system functions.
Please also remember that if you choose to provide personally identifiable information using certain public features of our Service, individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through our Service.
Except as provided by law, the Company undertakes not to sell, rent, exchange, or otherwise transfer personal data of Users to third parties without the explicit consent of the Users.
We have the right to grant access to the User’s personal data to a third party under the following circumstances:
For behavior statistics, business intelligence, and email campaigns we use the service by Google LLC (“Google Analytics”), a company located in the United States. Data that we may provide to Google Analytics may include your IP address and that data is used by Google Analytics to generate information about your usage of our Service. We may also use Yandex Metrica for similar purposes and may provide similar data to them. Data provided to Yandex Metrica may also include your IP address.
In addition to the specific disclosures of personal data, we may also disclose your personal data:
a) to our auditors, lawyers, accountants, consultants, and other professional advisors insofar as it is reasonably necessary for the purposes of obtaining professional advice or managing legal disputes and risks;
b) where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests and/or the vital interests of a third-party;
c) as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users.
We use Google Analytics to analyze the use of our Service. Google Analytics, among other methods, also gathers information about Service use by means of cookies. The information gathered relating to our Service is used to create reports about the use of our Service and how we might improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit. We may also use Yandex Metrica for similar purposes.
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Disabling cookies will result in disabling most features of this Service. Therefore, it is recommended that you do not disable cookies.
You have the right to download, access, and request the deletion of your Personal Data that we hold about you, in accordance with GDPR regulations. If you wish to exercise these rights, please send an email to support@roulette.chat. We may ask you to verify your identity before processing your request to ensure your data’s security and compliance with applicable laws.
Other websites may contain links to our Service. We use our commercially reasonable efforts to make sure that they are not involved in any illegal activities and are GDPR compliant. Yet, these websites are not under our control and are not subject to this Privacy Policy. They will likely have their own privacy notices and terms of use. We have no responsibility for these websites. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your personal data.
We reserve the right to place external links to websites and third-party goods throughout our service. We attempt to always provide links and URLs to respected websites; however, we do not accept responsibility for any contents, security, or actions taken on such websites. When you navigate to any third-party website, any personal data that you provide is managed exclusively by the privacy policy of that particular website, and we do not assume any responsibility for the data you decide to provide.
CSAM stands for child sexual abuse material. It is illegal and our Terms of Service prohibit using Company products and services to store or share this content. CSAM consists of any visual depiction, including but not limited to photos, videos, and computer-generated imagery, involving the use of a minor engaging in sexually explicit conduct.
Roulette Chat strictly prohibits any form of Child Sexual Abuse and Exploitation (CSAE). Users are explicitly forbidden from engaging in any activity that involves CSAE, including but not limited to:
If you encounter any content or behavior that you believe involves CSAE, please report it immediately through our in-app reporting mechanism or by contacting us at support@roulette.chat with the subject line “CSAM Report.”. All reports will be reviewed promptly, and appropriate actions will be taken, including the removal of content and notification of relevant authorities in compliance with applicable laws.
Roulette Chat takes reports of Child Sexual Abuse and Exploitation (CSAE) very seriously. When a report is made, we will review the content and take appropriate action, which may include removing the content and notifying relevant authorities such as the National Center for Missing and Exploited Children (NCMEC) or other regional authorities. User data related to these reports will be handled in accordance with applicable privacy laws and only shared with necessary parties for the purpose of investigation and enforcement.
We provide an in-app mechanism for users to submit feedback, concerns, or reports regarding any content or behavior on the App. To report any inappropriate content or behavior, including CSAE, please use the “Report” feature within chat interactions and send your report to support@roulette.chat with the subject line “CSAM Report”.
Our Service is not designed for use by anyone under the age of 18 or who has not reached the age of majority established in your country. We do not knowingly collect personal data from children under the age of 18, and we undertake all possible measures to prevent access to our Service by individuals below the mentioned age limit.
If you believe that we may have Personal Data about or collected from a child under the specified age in the relevant jurisdiction without the consent of their parent or guardian, please contact us at support@roulette.chat.
We are entitled to investigate complaints or reported violations and to take any action we deem appropriate, including, but not limited to, reporting any suspected unlawful activity to law enforcement officials, regulators, or other third parties and disclosing any information necessary or appropriate to such persons or entities relating to your profile, email addresses, usage history, posted materials, IP addresses, and traffic information.
For your protection and the protection of all of our members, we may ask you for information to verify your identity or authority to act on behalf of a member before we can answer the above requests. We wouldn’t want someone else to get control of your data!
Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another member, such as a copy of any messages you received from them, the other member will have to make a request themselves.
This section sets out our data retention and deletion policies, which are designed to help ensure that we comply with our legal obligations in relation to the User’s right to be forgotten.
Personal data will be retained in a form that allows identification of users only for as long as necessary to fulfill our business purposes.
Users may request the deletion of their account through our Service.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the period we need to access the data for the provision of services, receiving payment, resolving your customer support issue, or other issues, or for any other auditing or legal reasons.
We may retain your personal data for a reasonable period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
For any inquiries or to exercise your data protection rights, please contact us at support@roulette.chat.