Last updated: Mar 23, 2023

Welcome to ClikChat (the "Platform"). The Platform is provided and controlled by ClikPals Network Limited., with its registered address at Tusker House 108, Nairobi, Kenya ("ClikChat", "we" or "us").

We are committed to protecting and respecting your privacy. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform.

If you have any questions about how we use your personal data, contact us at: privacy@clik.chat

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at ClikChat unless otherwise defined in this Privacy Policy.

Summary

What information do we collect about you?

We collect and process the information you give us when you create an account and upload content to the Platform. This includes technical and behavioural information about your use of the Platform. We also collect information about you if you download the app and interact with the Platform without creating an account.

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it. We use your information to, among other things, show you suggestions in the "For You"/"Friends" feed, improve and develop the Platform and ensure your safety. Where appropriate, we will also use your personal information to serve you targeted advertising and promote the Platform.

Who do we share your information with?

We share your data with third-party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with business partners, other companies in the same group as ClikChat, content moderation services, measurement providers, advertisers, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise or defence of legal claims.

How will we notify you of any changes to this Privacy Policy?

We will generally notify all users of any material changes to this policy through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the "Last Updated" date at the top of this policy, which reflects the effective date of such policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

How can you review, update or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. The Platform provides a way to review and update this information in your Profile. To request to delete your personal information, please send us an email: privacy@clik.chat.

The types of personal data we use

We collect and use the following information about you:

Your Profile Information

You give us information when you register on the Platform, including your username, password, date of birth (where applicable), email address and/or telephone number, the information you disclose in your user profile, and your photograph or profile video.

User Content and Behavioural Information

We process the content you generate and view on the Platform, including preferences you set (such as choice of language) photographs, audio and videos you upload or create, comments and live streams you make ("User Content"). We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content, in order to recommend audio options and provide other personalized recommendations. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect. We may collect information about the images and audio that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this information to enable special video effects, for content moderation, for demographic classification, for content and ad recommendations, and for other non-personally-identifying operations. We may access content, including text, images, and video, found in your device's clipboard, with your permission. For example, if you choose to initiate content sharing with a third- party platform, or choose to paste content from the clipboard into the ClikChat App, we access this information stored in your clipboard in order to fulfill your request. We collect information through surveys, challenges and competitions in which you participate. We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the ads you view, videos you watch and problems encountered, the content you like, the content you save to 'My Favourites', the users you follow and how you engage with mutual followers. We also infer your preferences, including your interests, gender and age for the purpose of personalising content. We process information about your followers, the likes you receive and responses to content you upload, for the purposes of promoting your content to other users and exploring whether your profile presents further opportunities for collaboration. Where appropriate, we will also use this information for the purpose of serving personalised advertising and to tell you about new services and opportunities.

Information from Third Parties

You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third-party data automatically. We have set out further detail on the information we receive from third parties below:

Business Partners

If you choose to register or use the Platform using a third-party social network account details (e.g., Facebook, Twitter, Instagram, Google) or login service, you will provide us or allow to provide us with your username, public profile, and other possible information related to such account. We will likewise share certain information with your social networks such as your app ID, access token and the referring URL. For further information on sharing your Facebook contact list with us, please see Find other users and invite your friends. If you link your ClikChat account to another service, we may receive information about your use of that service.

Advertisers, Advertising Networks, and Analytic Providers

We use the information collected from you, and your interaction with the Platform and other third-party sites and Apps, to infer your likely interests to provide you with more relevant advertising. This information tells us about websites you've visited, apps you've downloaded and purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and similar technologies on our Platform and from similar information received from third parties who advertise on our Platform and whose sites/Apps you visit.

Technical Information we collect about you

We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform.

Location

Location. We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS).

Find other users and invite your friends

You can choose whether to find other users of the Platform using our 'Find Friends' function. This functionality allows you to see which of your friends from either your telephone's contact list or Facebook friends list is using the Platform and offers you the option to follow them. You can also use this function to invite your contacts to join you on the Platform. We will use the contact information you have for that person, either from within your telephone's contact list or Facebook friends list and give you the option to send them either an SMS, email or third-party message (such as Whatsapp, Facebook (including Facebook Messenger) or Twitter) inviting them to view your ClikChat profile.

In-App purchases

If you reside in certain jurisdictions that offer in-app coin purchases, please note the provisions of our Virtual Items Policy. Your purchase will be made via your Apple iTunes or Google Play account. We do not collect any financial or billing information from you in relation to such a transaction. Please review the relevant app store's terms and notices in respect of the handling of such data. So that we can credit your account with the correct value in coins, we keep a record of the purchases you make, the time at which you make those purchases and the amount spent. In addition to in-app coin purchases, if you choose to make other payment related transactions the Platform may collect payment information, including payment card numbers or other third-party payment information (such as PayPal) where required for the purpose of payment.

Proof of your identity or age

We sometimes ask you to provide proof of identity or age in order to use certain features, such as livestream or verified accounts, or when you apply for a Pro Account, ensure that you are old enough to use the Platform, or in other instances where verification may be required.

Cookies

We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across your devices. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.

Additionally, we allow our business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across your devices, using your email or other log-in or device information. These third parties may use this information to display advertisements on our Platform and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt-out, so you may need to opt-out separately for each browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

How we use your personal data

We will use the information we collect about you in the following ways:

  • notify you about changes to our service;
  • provide you with user support;
  • personalise the content you receive and provide you with tailored content that will be of interest to you;
  • enable you to share User Content and interact with other users;
  • enable our messenger service to function if you choose to use this function;
  • enable you to participate in the virtual items program;
  • communicate with you;
  • to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform;
  • ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;
  • ensure content is presented in the most effective manner for you and your device;
  • improve, promote and develop the Platform and promote popular topics, hashtags and campaigns on the Platform;
  • carry out data analysis and test the Platform to ensure its stability and security;
  • allow you to participate in interactive features of the Platform;
  • to enable you to socialise on the Platform, for example, by allowing other users to identify you via the "Find other friends" function or through their phone contacts;
  • to ensure that you are old enough to use our Platform (as required by law).
  • provide you with personalised advertising;
  • provide you with location-based services (where those services are available in your jurisdiction);
  • To inform our algorithms;
  • enforce our terms, conditions and policies;
  • administer the Platform including troubleshooting; and
  • to facilitate sales, promotion, and purchase of goods and services and to provide user support;

How we share your personal data

We share your data with the following selected third parties:

Business Partners

If you choose to register to use the Platform using your social network account details (e.g., Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your phone number, email address, username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.

Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.

Payment Providers

If you choose to Buy Coins or conduct other payment related transactions, we will share data with the relevant payment provider to facilitate this transaction. For Coin transactions, we share a transaction ID to enable us to identify you and credit your account with the correct value in coins once you have made the payment.

Service Providers

We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place and service providers that assist us in marketing the Platform.

Analytics Provider

We use analytics providers to help us in the optimisation and improvement of the Platform. Our third-party analytics providers also help us serve targeted adverts.

Advertisers and Advertising Networks

We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We share your device ID with measurement companies so that we can link your activity on the Platform with your activity on other websites; we then use this information to show you adverts which may be of interest to you.

Our Corporate Group

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.

Law Enforcement

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

  • comply with legal obligation, process or request;
  • enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).


Public Profile

Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. Alternatively, you can change your profile to default private by changing your settings to 'Private Account' in “Manage my account” settings.

Sale or Merger

We will also disclose your information to third parties:

  • in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
  • if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

Where we store your personal data

The personal data we collect from you may be stored on a server located in Kenya or the United States, outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.

Your Rights and Choices

You can access and edit most of your profile information by signing into ClikChat. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your videos, send you messages, or post comments to your videos. Should you choose to do so, you may delete your entire account in Settings. You may also be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. If you have any questions on how to use the above tools, want to know about what rights you may have or want to exercise them, or have any requests, inquiries, or complaints, please contact us at: privacy@clik.chat

The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

How long we keep your personal data

We retain your information for as long as it is necessary, for example, to comply with our contractual relationship or to provide you with our service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data, as may be allowed by applicable laws. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.

Information relating to children

ClikChat is not directed at children under the age of 13. In certain cases, this age may be higher due to local regulatory requirements, please see your local privacy policy for more information. If you believe that we have personal data about or collected from a child under the relevant age, contact us at: privacy@clik.chat.

Complaints

In the event that you wish to make a complaint about how we process your personal data, contact us immediately at: privacy@clik.chat. We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

Contact

If you have questions, comments, or requests regarding this policy, contact us at: privacy@clik.chat.