PRIVACY POLICY

Effective Date: March 2, 2026

Welcome to Chato. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services.

1. Introduction and Scope

1.1. About Chato: Chato is a professional haircare community platform designed for users to share styling tips, product reviews, and hair transformation journeys. 1.2. Agreement: By downloading, accessing, or using the Chato App, you agree to the terms of this Privacy Policy. If you do not agree with these terms, please do not access the application. 1.3. Applicability: This policy applies to all personal information collected through our mobile app, website, and any related services, sales, marketing, or events. 1.4. Entity: References to "we," "us," or "our" refer to the Chato team and its designated operators.

2. Information We Collect

2.1. Account Information: When you register for Chato, we collect information such as your name, email address, age, gender, and profile picture. 2.2. Personal Hair Profile: To provide personalized recommendations, we may collect data regarding your hair type, texture, scalp condition, and haircare goals that you voluntarily provide. 2.3. User-Generated Content (UGC): We collect the content you create, upload, or share on the platform, including photos of hairstyles, videos, comments, reviews, and private messages sent through our chat features. 2.4. Device and Technical Data: We automatically collect certain information when you visit the App, including your IP address, device ID (IDFA/GAID), hardware model, operating system version, unique device identifiers, and mobile network information. 2.5. Usage Data: We track your interactions within the App, such as the posts you like, users you follow, search queries, and the time and duration of your activities. 2.6. Location Data: With your permission, we may collect precise or approximate location data to suggest local salons or community members nearby. You can disable this via your device settings.

3. How We Use Your Information

3.1. Service Provision: To create and manage your account, provide access to community features, and ensure the App functions correctly on your device. 3.2. Personalization: To tailor the content you see, including recommending hair tutorials, styling tips, and community discussions based on your hair profile and interests. 3.3. Community Interaction: To enable social features such as commenting, following, and direct messaging between users. 3.4. Safety and Security: To monitor and prevent fraudulent activity, protect the integrity of our community, and enforce our Terms of Service. 3.5. Analytics and Improvement: To understand user behavior trends, perform troubleshooting, and develop new features to enhance the Chato experience. 3.6. Marketing and Communication: To send you administrative updates, security alerts, and, with your consent, promotional information about new haircare trends or platform features.

4. Information Sharing and Disclosure

4.1. With Your Consent: We may share your information with third parties when you give us explicit permission to do so. 4.2. Service Providers: We share data with trusted third-party vendors who perform services for us, such as cloud hosting (e.g., AWS/Google Cloud), data analytics, and customer support tools. 4.3. Business Partners: We may share limited information with haircare brands or salons if you engage with their sponsored content, but only in accordance with your privacy settings. 4.4. Legal Obligations: We may disclose your information where required by law, such as in response to a subpoena, court order, or legal process. 4.5. Public Profile: Please note that your username, profile picture, and any UGC you post to public areas of the App are visible to other users.

5. User-Generated Content (UGC) Policy

5.1. Content Ownership: You retain ownership of the photos and text you post on Chato. However, by posting, you grant us a non-exclusive, royalty-free, worldwide license to use, store, and display your content to provide our services. 5.2. Content Collection and Storage: UGC is collected and stored on our secure servers to ensure it is available across your devices and to other community members. 5.3. Moderation: We use a combination of automated AI tools and human moderators to review UGC for violations of our community guidelines, including prohibited content (e.g., hate speech, nudity). 5.4. Public Exposure: Any content you share in public forums or on your profile may be indexed by search engines or shared by other users outside of the App. 5.5. Reporting Mechanism: We provide tools for users to report inappropriate UGC. We reserve the right to remove any content that violates our policies or infringes on third-party intellectual property rights.

6. Data Retention and Storage

6.1. Retention Period: We retain your personal information for as long as your account is active or as needed to provide you with the Chato services. 6.2. Legal Necessity: We may retain certain information for longer periods if required by law, such as for tax, accounting, or anti-fraud purposes, or to resolve disputes and enforce our agreements. 6.3. De-identification: When we no longer have a legitimate business need to process your personal information, we will either delete it or anonymize it so that it can no longer be associated with you. 6.4. Backup Storage: Please note that even after you delete your account or information, residual copies may remain in our backup systems for a limited time before being permanently purged.

7. Data Security Measures

7.1. Security Standards: We implement industry-standard technical and organizational security measures designed to protect the integrity and confidentiality of your data, including encryption (SSL/TLS) for data in transit and at rest. 7.2. Access Control: Access to your personal data is strictly limited to authorized employees, contractors, and agents who need to know that information to process it for us and who are subject to strict contractual confidentiality obligations. 7.3. User Responsibility: While we strive to protect your information, no method of transmission over the internet is 100% secure. You are responsible for maintaining the secrecy of your unique password and account information. 7.4. Vulnerability Management: We regularly conduct security audits and vulnerability scans to identify and remediate potential threats to our platform. 7.5. Breach Notification: In the event of a confirmed data breach that puts your personal information at risk, we will notify you and the relevant regulatory authorities in accordance with applicable laws.

8. International Data Transfers

8.1. Global Operations: Chato is a global haircare community. By using the App, you acknowledge that your information may be transferred to, stored, and processed in countries other than your own (including but not limited to the United States, Singapore, and Ireland). 8.2. Data Protection Laws: These countries may have data protection laws that are different from the laws of your country. However, we ensure that appropriate safeguards are in place to protect your data. 8.3. Standard Contractual Clauses: We rely on Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent legal mechanisms for the transfer of data from the EEA, UK, or Switzerland to third countries. 8.4. Consent to Transfer: By providing your information, you consent to this international transfer, storage, and processing.

9. Your Privacy Rights and Choices

9.1. Access and Portability: You have the right to request copies of your personal data held by us. You can also request that we provide this data in a structured, machine-readable format. 9.2. Correction and Update: You can update your profile information directly within the App settings. If you find any inaccuracies you cannot correct yourself, you may contact us for assistance. 9.3. Right to Erasure (Right to be Forgotten): You may request the deletion of your account and associated personal data at any time through the App settings or by emailing our support team. 9.4. Withdrawal of Consent: Where we rely on your consent to process data (e.g., location access or marketing), you may withdraw that consent at any time via your device settings or the "Unsubscribe" link in emails. 9.5. Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights, such as by denying you services or charging different prices.

10. Cookies and Tracking Technologies

10.1. Use of Cookies: We and our partners use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities and to remember your preferences. 10.2. Mobile Identifiers: On mobile devices, we use Advertising IDs (such as Apple's IDFA and Google's GAID) to provide personalized content and analyze the effectiveness of our marketing campaigns. 10.3. Third-Party SDKs: We integrate third-party Software Development Kits (SDKs) for analytics (e.g., Firebase, AppsFlyer) and social sharing. These SDKs may collect data directly from your device. 10.4. Opt-Out Options: You can manage your cookie preferences through your browser settings or limit ad tracking via the "Privacy" settings on your iOS or Android device. 10.5. Do Not Track: Please note that our systems may not currently respond to "Do Not Track" signals from web browsers, as no industry standard has been established.


11. Children's Privacy and Age Restrictions

11.1. Age Requirement: Chato is strictly intended for individuals who are at least 18 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 18. 11.2. Verification: We reserve the right to request age verification at any time to ensure that minors are not using the service. 11.3. Child Sexual Abuse and Exploitation (CSAE): We have a zero-tolerance policy regarding Child Sexual Abuse and Exploitation. We employ proactive technologies (such as digital fingerprinting and AI-driven image hashing) to detect, prevent, and remove any content related to CSAE. We strictly comply with mandatory reporting requirements and will report any instances of CSAE to the National Center for Missing & Exploited Children (NCMEC) and relevant law enforcement agencies globally. 11.4. Reporting and Deletion: If we become aware that a person under 18 has provided us with personal information, we will delete such information and terminate the user's account immediately. If you believe we might have any information from or about a child under 18, please contact us at service@tina.rocks.

12. Sensitive Personal Information

12.1. Definition: Some information you voluntarily provide, such as specific scalp conditions or medical-related hair loss details, may be considered "Sensitive Personal Information" under certain jurisdictions (e.g., GDPR or CCPA). 12.2. Explicit Consent: By providing this information to receive personalized haircare advice, you grant your explicit consent for us to process this sensitive data solely for the purpose of enhancing your user experience. 12.3. Limited Use: We do not use or disclose sensitive personal information for purposes other than those necessary to provide the services or as permitted by law. 12.4. Withdrawal: You may remove or modify your hair profile data at any time via the "Edit Profile" section of the App.

13. Push Notifications and Communications

13.1. Service Alerts: We may send you push notifications regarding your account activity, such as comments on your posts, new followers, or security updates. 13.2. Marketing Notifications: With your consent, we may send you notifications about trending hairstyles, product launches, or community events. 13.3. Opt-Out: You can opt-out of receiving push notifications at any time by adjusting the settings on your mobile device or within the Chato App settings menu. 13.4. Email Communications: We may send you administrative emails or newsletters. You can opt-out of promotional emails by clicking the "Unsubscribe" link included in each message.

14. Third-Party Links and Integrations

14.1. External Links: The App may contain links to third-party websites (e.g., professional salon sites or e-commerce platforms). We are not responsible for the privacy practices or content of these external sites. 14.2. Social Media Logins: If you choose to register or log in using a third-party service (such as Google or Apple), we receive certain profile information from that provider as authorized by your settings with them. 14.3. Embedded Content: Content from third parties (e.g., embedded YouTube tutorials) may use their own cookies or tracking technologies. Your interaction with such content is governed by the privacy policy of the providing company.

15. California Privacy Rights (CCPA/CPRA)

15.1. Notice for California Residents: This section applies specifically to users residing in California. We provide these disclosures to comply with the California Consumer Privacy Act (CCPA). 15.2. Right to Know: You have the right to request a disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months. 15.3. Right to Delete: You have the right to request the deletion of personal information we have collected from you, subject to certain legal exceptions. 15.4. Do Not Sell or Share: Chato does not "sell" your personal information to third parties for monetary compensation. However, we may "share" information for cross-context behavioral advertising. You have the right to opt-out of such sharing. 15.5. Exercise of Rights: California users may exercise their rights by contacting us at service@tina.rocks with the subject line "California Privacy Request."

16. Additional Information for EEA and UK Users (GDPR)

16.1. Legal Basis for Processing: If you are located in the European Economic Area (EEA) or the United Kingdom (UK), we process your personal data under the following legal bases: (a) Performance of a contract; (b) Your explicit consent; (c) Our legitimate business interests; and (d) Compliance with legal obligations. 16.2. Data Controller: The entity responsible for processing your data is the Chato team. 16.3. Right to Complain: You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe our processing of your personal data infringes on applicable data protection laws. 16.4. Automated Decision-Making: We do not use your personal data for automated decision-making that produces legal effects or significantly affects you, except for security and moderation purposes.

17. Changes to This Privacy Policy

17.1. Right to Update: We may update our Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. 17.2. Notification of Changes: If we make material changes, we will notify you by posting the new Privacy Policy within the App, sending an in-app notification, or emailing you at the address associated with your account. 17.3. Review Frequency: We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. 17.4. Acceptance of Terms: Your continued use of the Chato App after the "Effective Date" of any changes constitutes your acceptance of the updated Privacy Policy.

18. Contact Information and Data Protection Officer

18.1. General Inquiries: If you have any questions, concerns, or comments about this Privacy Policy or our privacy practices, please contact us at service@tina.rocks. 18.2. Privacy Requests: To exercise your rights (such as data access or deletion), please send an email with the subject line "Data Privacy Request" to ensure prompt handling. 18.3. Response Time: We aim to respond to all legitimate requests within thirty (30) days. If a request is particularly complex, we will notify you and keep you updated on the progress.

19. Governing Law and Dispute Resolution

19.1. Jurisdiction: This Privacy Policy and any disputes arising out of or related to it shall be governed by and construed in accordance with the laws of the jurisdiction where our company is headquartered, without regard to its conflict of law principles. 19.2. Amicable Settlement: We prefer to resolve any concerns you may have through direct communication. Please reach out to us first before initiating any formal legal proceedings. 19.3. Arbitration: Any dispute that cannot be resolved informally shall be settled through binding arbitration in accordance with international commercial arbitration rules, unless local mandatory law requires otherwise.

20. Entire Agreement and Language

20.1. Completeness: This Privacy Policy, together with our Terms of Service, constitutes the entire agreement between you and Chato regarding your privacy and data protection. 20.2. Severability: If any provision of this Privacy Policy is found to be invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect. 20.3. Language Version: This Privacy Policy is written in English. In the event of any discrepancy between the English version and any translated version, the English version shall prevail.


Privacy Policy Conclusion

Thank you for being a part of the Chato community. We are dedicated to providing you with a safe and inspiring environment to share your haircare journey.