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Privacy Policy

Effective date: October 24, 2026

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Cofy Chat is a voice-calling app that connects you with friends and mutual contacts for short, voice-only calls. This Privacy Policy explains what information we collect, why, how we use and share it, how long we keep it, and the choices and rights you have. It applies to the Cofy Chat mobile app and the cofychat.com website.

The short version: we collect only what the app needs to work. We do not sell your personal data or share it for cross-context behavioural advertising. We do not show you ads. We do not track you across other companies’ apps or websites. And we never record your calls, your voice is transmitted live and is not stored by us.

1. Who we are

Cofy Chat is operated by Javtesh Singh Bhullar, operating as Cofy Chat, a sole proprietorship registered in Ontario, Canada (the data controller). Postal address: 63-7115 Rexwood Rd, Mississauga, Ontario L4T 4L4, Canada. Contact: hi@cofychat.com.

Accountable person (Canada / PIPEDA). Cofy Chat is accountable for the personal information under its control. For any question about our compliance with this policy or applicable Canadian privacy law, contact us at hi@cofychat.com.

Privacy Officer (Quebec, Law 25). You can reach the person responsible for the protection of personal information at hi@cofychat.com.

Data Protection Officer (GDPR). We are not required to appoint a Data Protection Officer under Article 37 of the GDPR, and we have not appointed one. For any data-protection question, contact hi@cofychat.com.

Contacting us from the EU, EEA, or UK. For any privacy or data-protection matter, contact us at hi@cofychat.com. You also have the right to complain to your local supervisory authority (see “Your rights and choices” below).

2. Information we collect

Account information. When you sign up we collect your phone number (used to verify your account by SMS one-time code and to let friends who already know you find you), your name, a username, your country, and an optional profile photo.

How you found us. If you answer the optional “how did you hear about us?” question, we keep your answer to understand which channels bring people to Cofy Chat.

Friends and connections. The friend lists you build in the app (your Weekly, Bi Weekly, and Monthly lists), who has added you, users you have blocked, and any private notes you attach to a contact. Private notes are visible only to you, never to the other person.

Mutual-contact graph and discoverability. To enable calls with people you actually know, we derive and store which other Cofy Chat users are mutual contacts of yours (you each have the other’s number). We also store your “discoverable by phone” preference (whether people who have your number can find you on Cofy Chat) so that we honour it.

Call information. When you place or receive a call we keep basic records: who called whom, when a call was placed and whether and when it connected, how long it lasted, and the call type (this includes call attempts, not only connected calls). We use this to run the app (for example, your call balance and the “don’t repeat the same friend too soon” logic). Calls are not recorded. Your voice is transmitted in real time and is not stored by us.

Game activity. When you and a friend play one of the in-call games, we store that game’s state on our servers while you play: whose turn it is, the moves made, and the score, so both phones stay in sync. It is linked to the accounts playing. Solo games are played on your device, and we do not receive the moves you make or the score you reach, only the fact that you cleared a game that earns bonus call credits and how many it earned, so we can add them to your balance.

Device contacts (contact discovery). To show you which of your contacts are already on Cofy Chat, the app sends your contacts’ phone numbers to our server to check them against Cofy Chat accounts. We use the numbers only to perform that match and return your results, we do not log or store them on our servers, and numbers that don’t match a Cofy Chat account are discarded. Your matches are cached on your device so the app doesn’t re-check every time. Contacts permission is requested only when you use this feature, and you can turn it off in device Settings.

When you use contact discovery, the phone numbers in your address book may include people who are not Cofy Chat users. We receive those numbers solely to check for a match, do not store them, and discard non-matches immediately; we do not build profiles of non-users or contact them.

Credits, promo codes and bonuses. We keep a record of your call credits and of the promotional, referral, share-to-earn, and bonus credits you earn or redeem, so we can apply them to your account and prevent abuse. Credits have no cash value.

Purchases. If you subscribe to a paid plan, the payment is processed entirely by Apple (App Store) or Google (Google Play), depending on where you subscribe. We receive subscription status (which plan, whether it’s active, when it renews or expires) through Apple or Google Play and our subscription-management provider RevenueCat. We never see your payment-card details.

Usage and analytics. Where you consent (and where consent is required in your region), we collect app-usage events (for example: app opens, viewing the upgrade screen, starting or completing a purchase) and basic device information through PostHog and Google Analytics for Firebase, our product-analytics providers, to understand how the app is used and improve it. Both are governed by the same “Usage analytics” switch in Settings and are consent-gated in the EU/EEA, the UK and Switzerland: they stay off until you turn them on, and turning the switch off stops collection in both. Neither is used for advertising, and neither tracks you across other companies’ apps or websites.

Approximate location. The app never asks for location permission, and we never collect GPS or precise location. Our analytics providers do see the IP address your analytics events are sent from and derive an approximate location from it, typically no more precise than a city. We use it only to understand roughly where our users are. It is part of the analytics described above, so the same “Usage analytics” switch controls it, and it stays off by default in the EU/EEA, the UK and Switzerland until you turn it on.

Notifications. A push-notification token for your device, so we can deliver calls and in-app notifications. This includes occasional reminder notifications (for example letting you know when friends are around), you can turn these off in the app while keeping call notifications.

Safety reports and things you send us. Feedback, feature requests, bug reports, and safety reports you submit in the app. This also includes reports that other users file about you, which we keep in order to review them and enforce our rules.

Crash, performance and diagnostic data. To find and fix faults we collect crash and diagnostic reports through Firebase Crashlytics and Firebase Sessions: the point in our code where the app stopped, your device model and iOS or Android version, the app version and session, and errors that did not crash the app. These reports carry no account identifier, so they are not linked to you, and they never include your calls, your contacts, or who you talked to. Unlike analytics, crash reporting is on by default everywhere; you can turn it off at any time in Settings → Account & Support → Privacy & Alerts → Crash reports.

3. How we use your information

  • To operate the app: verify your account, connect calls between you and your friends and mutual contacts, run contact discovery, manage your call balance, credits and subscription, run the in-call games, and deliver notifications.

  • To keep the community safe: enforce blocks, screen profile photos and display names/usernames, review safety reports, and prevent abuse and fraud.

  • To improve the app: understand which features are used and fix problems (analytics, where you have consented).

  • To support you: respond when you contact us.

We do not sell your personal information, use it for third-party advertising, or track you across other companies’ apps and websites.

Legal bases for processing (EU / EEA / UK)

If you are in the EU, EEA, or UK, we must tell you the legal basis we rely on under Article 6(1) of the GDPR:

  • Performance of a contract (Art. 6(1)(b)): to provide the app you asked for: verifying your account, connecting your calls, running contact discovery, managing your friend lists, call balance, credits and subscription, and delivering call/notification alerts. Without this data the app cannot function.

  • Legitimate interests (Art. 6(1)(f)): to keep the service secure and prevent abuse and fraud (for example App Check and our anti-abuse logic), and to deliver push notifications reliably. Where we rely on legitimate interests we have weighed those interests against your rights; you can object at any time (see “Your rights”).

  • Consent (Art. 6(1)(a)): for optional, non-essential analytics where consent is required in your region (EU/EEA/UK), and for the device permissions you grant (contacts, microphone, notifications, and on Android nearby devices, for Bluetooth headsets in a call). You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal; withdrawing a permission simply turns off the related feature.

  • Legal obligation (Art. 6(1)(c)): where we must retain certain records (for example tax/transaction records relating to purchases) or respond to lawful requests.

Providing your phone number, name, username and the other account data above is a contractual requirement: it is necessary to create an account and use the app, and if you do not provide it we cannot give you an account. The table below shows the basis that applies to each data type.

  • Phone number (account identifier; SMS one-time code; friend discovery). Purpose: create and verify your account and connect users. Legal basis: contract, Art. 6(1)(b).

  • Name and username (profile identity). Purpose: display your identity and let friends find you. Legal basis: contract, Art. 6(1)(b).

  • Profile avatar (optional profile photo). Purpose: personalise your profile. Legal basis: contract, Art. 6(1)(b), optional but part of the service you request.

  • Push notification token (device notification token). Purpose: deliver call and notification alerts. Legal basis: contract, Art. 6(1)(b) for core delivery, and legitimate interests, Art. 6(1)(f), for reliable and secure delivery.

  • Call metadata (who, when, duration and type; not call content). Purpose: run your call balance, the anti-repeat logic, and abuse prevention. Legal basis: contract, Art. 6(1)(b); the abuse-prevention element is also legitimate interests, Art. 6(1)(f).

  • Purchases and subscription status (plan, active state, and renewal or expiry, via Apple or Google Play and RevenueCat). Purpose: manage your subscription and entitlements. Legal basis: contract, Art. 6(1)(b); record-keeping is also a legal obligation, Art. 6(1)(c).

  • Credits, promo and bonus records (credit balances and promo redemptions). Purpose: apply credits and prevent abuse. Legal basis: contract, Art. 6(1)(b); the anti-abuse element is also legitimate interests, Art. 6(1)(f).

  • Analytics events (app-usage and interaction events via PostHog and Google Analytics for Firebase, consent-gated). Purpose: understand usage and improve the app. Legal basis: consent, Art. 6(1)(a), for EU, EEA and UK users, and legitimate interests, Art. 6(1)(f), where consent is not required.

  • Device contacts (contact phone numbers sent to our server for a transient match; not stored; non-matches discarded). Purpose: show which of your contacts are on Cofy Chat. Legal basis: consent, Art. 6(1)(a), for the device permission; the transient match is also necessary to provide the feature you request, so contract, Art. 6(1)(b).

  • Friend lists, blocks and private notes (connection and safety data). Purpose: operate the social graph and safety features. Legal basis: contract, Art. 6(1)(b); the safety element is also legitimate interests, Art. 6(1)(f).

  • Safety and abuse reports (including reports about you; reports and moderation records). Purpose: protect users and enforce our Terms. Legal basis: legitimate interests, Art. 6(1)(f); where applicable, a legal obligation, Art. 6(1)(c).

  • Game activity (in-call game state, moves and scores, linked to the accounts playing, and records of solo scores that earn bonus credits). Purpose: keep both players in sync during a game and apply any credits earned. Legal basis: contract, Art. 6(1)(b).

  • Approximate location (city- or country-level location derived from the IP address your analytics events are sent from; never GPS, and the app requests no location permission). Purpose: understand roughly where our users are so we can prioritise improvements. Legal basis: consent, Art. 6(1)(a), for EU, EEA and UK users, and legitimate interests, Art. 6(1)(f), where consent is not required.

  • Crash, performance and diagnostic data (the point in our code where the app stopped, your device model and iOS or Android version, the app version and session, and errors that did not crash the app; via Firebase Crashlytics and Firebase Sessions). It does not include your messages, your calls, your contacts, or who you talked to, and it is not linked to your account. Purpose: find and fix faults so the app works. Legal basis: legitimate interests, Art. 6(1)(f), which is our interest in a working, stable app. You can turn this off at any time in Settings → Account & Support → Privacy & Alerts → Crash reports, which is also how you object to this processing. Unlike analytics, it is on by default, including in the EU, EEA and UK: a crash report is a fault diagnosis rather than a profile of you, and turning it off by default would leave us unable to fix the faults that affect those users most.

4. Who we share it with

We are not in the business of selling data. We share personal data only with the service providers (“processors”) that run the app’s infrastructure, and only so they can provide their service to us:

  • Google LLC (Firebase): account verification, database, file storage, push delivery, app integrity (App Check), product-analytics events (Google Analytics for Firebase, consent-gated), and crash and diagnostic reporting (Firebase Crashlytics and Firebase Sessions). US.

  • Stream.io, Inc. (GetStream): real-time voice-call transmission and calling identity/tokens. US.

  • Google LLC (Google Cloud Vision): automated screening of profile images (SafeSearch). US.

  • RevenueCat, Inc.: subscription status and entitlements. US.

  • PostHog, Inc.: product-analytics events, consent-gated. US.

  • Apple Inc.: in-app purchase processing and push delivery. US.

  • Google LLC (Google Play): in-app purchase processing for the Android app. US.

  • Wix.com Ltd.: hosts our cofychat.com marketing site and the “early access” email sign-up form.

We require each provider by contract to protect your information to a standard consistent with this policy, to use it only to provide their service to us, and not to use it for their own purposes. We may also disclose information where required by law, or where necessary to protect the safety, rights, or property of our users, the public, or Cofy Chat.

5. Automated moderation

Some safety checks are automated: profile images are screened by an automated image classifier (Google Cloud Vision SafeSearch) and display names/usernames are screened for prohibited terms; abuse signals can lead to content being hidden or an account being restricted. A human reviews reports and can review an automated action, contact hi@cofychat.com.

If you are in the EU: you can notify us of content you consider illegal by emailing hi@cofychat.com (notice-and-action). If we restrict your content or account, we will, where required, provide a statement of the reasons and an opportunity to appeal by contacting the same address. Fuller detail is in our Terms of Use.

6. Security

Your data is encrypted in transit, and access is restricted by server-side security rules, for example, sensitive records such as your call balance and subscription state can only be changed by our servers, never directly by any app user. No method of transmission or storage is completely secure, but we work to protect your information.

7. How long we keep it, and deleting your account

When you delete your account (in the app, from Settings → Account & Support → Account → Delete Account) it is deactivated immediately; if you don’t log back in within 30 days it is permanently deleted. Permanent deletion removes your profile, public profile, username, account record, friend and mutual-contact data, blocks, private notes, profile photo, notification token, sign-in credentials, your call history, your call-credit and promo records, and the moderation records associated with your account. Deleting your account does NOT cancel an Apple or Google Play subscription. Cancel an Apple subscription in device Settings → your name → Subscriptions, and a Google Play subscription in the Google Play Store app → profile icon → Payments & subscriptions → Subscriptions.

A limited set of records is kept after your account is deleted, only for as long as necessary and for the specific reasons below:

  • Safety and abuse reports: reports you filed and reports filed about you, kept for a limited period to protect users and enforce our Terms.

  • Billing and purchase records: kept for payment-integrity purposes and otherwise as long as required by applicable tax and accounting law.

  • A one-way hashed form of your phone number: when your account is deleted we create and keep, for up to 365 days, a non-reversible (hashed) form of your phone number, together with a masked display version (for example +91••••••3210) and a count of prior deletions, solely to detect and prevent abuse, ban evasion, and repeat-deletion fraud. It cannot be used to contact you.

  • Copies already delivered to other users: for example a “Hi” you sent that sits in another person’s inbox is part of that other person’s data and stays with them.

  • Analytics events: PostHog events are tied to your account identifier and are held under PostHog’s retention settings; you can ask us to delete them by emailing hi@cofychat.com. Google Analytics for Firebase events are not linked to your account: they carry only a device-scoped identifier, which is reset if you turn analytics off, and they age out under Google’s retention setting.

  • Crash and diagnostic reports: not linked to your account. They carry no account identifier, so they cannot be traced back to you or retrieved by name. They age out automatically under Firebase Crashlytics’ retention window (approximately 90 days). Your on/off choice for crash reports is stored on the device rather than on your account, so it stays with the device rather than being deleted with your account.

While your account is active, we keep operational records (such as your call history and short-lived in-call data) only as long as necessary to run the service, and delete them automatically on a rolling basis. In-call game data (game state, moves and scores) is deleted automatically 30 days after the call. We keep purchase and tax records as long as required by law. Where we genuinely cannot state a fixed period, we keep data only as long as necessary for the purpose described and our legal obligations.

8. International data transfers

We and our service providers are based in and store data in the United States (and the Google Cloud regions we use). If you are outside the United States (including in the EU/EEA, UK, or Canada) your personal data will be transferred to and processed in the United States, which may not offer the same level of data protection as your home country.

Where we transfer personal data out of the EEA or UK, we rely on appropriate safeguards under Articles 44 to 49 GDPR, for our processors, the European Commission’s Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum (IDTA), and, where a processor is certified under it and we have confirmed that certification, the EU-U.S. Data Privacy Framework. You can request a copy of the safeguards by emailing hi@cofychat.com.

Quebec (Law 25, s. 17). Before disclosing personal information outside Quebec, we assess whether it will receive protection adequate to Quebec standards; the transfers above are made subject to that assessment and the contractual safeguards named here.

9. Your rights and choices

You can:

  • Edit your profile in the app at any time.

  • Revoke contacts, microphone, notification, nearby-devices (Android) or photo-saving (iPhone) permissions in your device Settings, the related features simply stop working.

  • Turn reminder notifications (such as “Friend Reminders”) on or off in the app, separately from call notifications.

  • Turn “Usage analytics” and “Crash reports” on or off at any time in Settings → Account & Support → Privacy & Alerts.

  • Delete your account in the app (from Settings); see “How long we keep it.”

  • Request a copy of your data (access and portability), correction, or deletion by emailing hi@cofychat.com.

Do Not Track. We do not track you across third-party sites or services, and we do not respond to “Do Not Track” (DNT) browser signals, because we do not perform the kind of cross-site tracking those signals are designed to control.

EU / EEA / UK (GDPR). You have the right to access, rectify, erase, restrict, or object to processing; to data portability; and to withdraw consent at any time (without affecting processing before withdrawal). Where we rely on legitimate interests, you can object at any time. You also have the right to lodge a complaint with a supervisory authority, in the EU/EEA, your national Data Protection Authority; in the UK, the Information Commissioner’s Office (ICO, ico.org.uk).

EU / UK consumer withdrawal (14 days). Where you purchase a subscription, EU and UK consumers may have a 14-day right of withdrawal. Because Apple is the seller (merchant of record) for all App Store purchases, this right (and any refund) is exercised through Apple (reportaproblem.apple.com), not through us. For Google Play purchases, Google Commerce Limited is the seller in the EU, EEA and UK, so this right (and any refund) is exercised through Google Play (support.google.com/googleplay/answer/7659581).

Canada. You may contact our accountable person (above) about our handling of your personal information, and you have the right to complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca). Quebec residents may complain to the Commission d’accès à l’information du Québec (CAI, cai.gouv.qc.ca).

California. California residents have additional rights, see “California privacy notice” below.

How to exercise. Email hi@cofychat.com. We may need to verify your request by confirming control of the phone number or account associated with the data; information you give us for verification is used only to verify the request. We respond within the timeframes required by applicable law.

10. California privacy notice (CCPA / CPRA)

This section applies to California residents and serves as our Notice at Collection under the California Consumer Privacy Act, as amended by the CPRA.

We do NOT sell your personal information, and we do NOT share it for cross-context behavioural advertising, as “sell” and “share” are defined under the CCPA/CPRA. We have not sold or shared the personal information of any consumer (including any consumer we know to be under 16) in the preceding 12 months. Because we do not sell or share, no “Do Not Sell or Share My Personal Information” opt-out action is required from you, and we do not provide a (non-functional) opt-out link.

Categories of personal information we collect, why, and who receives them (last 12 months):

  • Identifiers (name, username, phone number, account/online identifiers, IP address, device/push token (and, transiently, the phone numbers of your device contacts, submitted only to check for matches and then discarded)) to create and verify your account, connect calls, run contact discovery, deliver notifications, and secure the service. Disclosed to: Google/Firebase, Stream.

  • Commercial information (subscription plan, purchase/renewal status, credits), to manage your subscription and call balance. Disclosed to: Apple or Google Play (the store you bought from), RevenueCat.

  • Internet or other electronic network activity (app-usage and interaction events, and the IP address they are sent from, from which a coarse location such as country may be derived), to understand usage and improve the app. Disclosed to: PostHog and Google/Firebase (consent-gated).

  • Geolocation data, coarse only (an approximate city- or country-level location derived from the IP address your analytics events are sent from), to understand roughly where our users are. We do not collect precise geolocation and the app requests no location permission. Disclosed to: PostHog and Google/Firebase (consent-gated).

  • Audio information: your voice is transmitted in real time to connect calls. Calls are NOT recorded or stored. Transmitted through: Stream.

  • User-generated content (profile photo, feedback, safety reports, and in-call game activity such as moves and scores), to operate your profile, run the games, and keep the community safe. Profile photos are screened by Google Cloud Vision.

  • Crash, performance and diagnostic data (the point in our code where the app stopped, your device model and iOS or Android version, the app version and session, and errors that did not crash the app), to find and fix faults. Not linked to your account. Disclosed to: Google/Firebase. You can turn it off in Settings → Account & Support → Privacy & Alerts → Crash reports.

We do NOT collect: precise geolocation, Social Security / driver’s-licence / government-ID numbers, payment-card numbers (Apple or Google handles payment), or biometric information. We do not store your device address book on our servers; contact phone numbers are transmitted only for a transient match and then discarded (see “Information we collect”).

Sensitive personal information. We do not collect or process “sensitive personal information” (as defined by the CPRA) to infer characteristics, and we do not use any data for that purpose.

Your California rights: to know/access, delete, correct, opt out of sale/sharing (not applicable, we do not sell or share), limit the use of sensitive personal information (not applicable), and non-discrimination for exercising your rights. To exercise, email hi@cofychat.com or use the in-app deletion flow (from Settings). We verify your request by confirming control of the phone number or account associated with the data; verification information is used only to verify. You may use an authorized agent with proof of authorization. We respond within the timeframes required by law (generally 45 days, extendable once). Retention: see “How long we keep it.”

11. Children

Cofy Chat is intended for users aged 16 and older in all markets. It is not directed to anyone under 16 (or the higher minimum age required in your country), and we do not knowingly collect personal data from anyone under 16. If you believe someone under 16 has created an account, contact hi@cofychat.com and we will delete it.

12. Changes to this policy

If we make material changes we will update this page and the effective date above, and where required we will notify you in the app. Continued use of Cofy Chat after a change takes effect means you accept the updated policy.

13. Contact

Questions, privacy requests, or to reach our accountable person / Privacy Officer: hi@cofychat.com. Postal: 63-7115 Rexwood Rd, Mississauga, Ontario L4T 4L4, Canada.

Users in the EU/EEA and UK can also contact their local data-protection supervisory authority, see “Your rights and choices.”

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