Nigo Privacy Policy

1. Introduction

Welcome to Nigo ("Nigo", "we", "our," or "us"). We are committed to protecting your privacy and ensuring transparency about how we handle your information. This Privacy Policy explains how we collect, use, process, and safeguard your data when you use our video chat application and related services, including host wall and interest-based matching features (collectively, the "Services").

Data controller: For the purposes of the General Data Protection Regulation (GDPR), the Personal Information Protection Law (PIPL) and similar laws, Nigo acts as the data controller (and, where applicable, the "personal information handler") for the personal data we collect and process in connection with the Services, unless we state otherwise in a specific notice.

Your trust is fundamental to our mission. We encourage you to read this policy carefully to understand your privacy rights and how we operate. By accessing or using our Services, you acknowledge that you have read and understood this policy in its entirety. If you do not agree with any part of this policy, please discontinue use of our Services immediately.

For questions about this policy or your personal information, contact us at privacy@nigo.com or support@nigo.com. We strive to respond to all inquiries within 10 business days.

2. Information We Collect

We collect information necessary to provide, maintain, and improve our Services, while prioritizing your privacy and security. The data we gather falls into the following categories:

2.1 Information You Provide Directly

Account Information: When creating an account, you provide basic details such as your username, email address. This information is essential for account creation, identity verification, and security management.
Profile Data: To enhance your experience and matching capabilities, you may optionally provide additional profile information including age and gender, profile photographs, biographical information, interests and preferences (e.g., music, travel, gaming), and other details you choose to share on your host wall profile.
Communication Content: All content you generate through our Services, including text messages and chat content, photos and videos shared in chats, voice messages and notes, and reactions and interactions in one-on-one or group conversations.
Customer Support Communications: When you contact our support team, we collect your contact information, account details (if applicable), details about your inquiry or issue, and any supporting materials you provide (e.g., screenshots).

2.2 Information Collected Automatically

Usage Data: Features and functions you use, session frequency duration and timing, matching activity and success rates, content engagement metrics, and navigation paths through the application.
Device Information: Device hardware specifications (model, manufacturer, screen size), operating system and version information, system language and regional settings, Device ID and unique device identifiers (e.g., advertising ID, hardware identifier, or similar persistent identifiers used to recognize your device), network information (IP address, connection type, service provider), and application performance data and crash reports. We collect Device ID to provide and secure our Services, prevent fraud, and support technical operations.

2.3 Information from Third Parties

Social Media Integration: If you choose to register through third-party services (e.g., Google, Apple, Facebook), we receive basic profile information from these providers as permitted by your account settings with them.
Service Partners: We may receive aggregated or anonymized data from trusted partners to improve our matching algorithms and service quality.

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Provision and Maintenance

Enabling core functionality including video calls, messaging, and matching features
Maintaining account security and facilitating account recovery
Providing technical support and troubleshooting
Ensuring service compatibility across different devices and platforms

3.2 Service Improvement and Development

Analyzing usage patterns to identify popular features and areas for improvement
Fixing bugs and resolving performance issues
Developing new features and functionality based on user behavior and feedback
Conducting research and analysis to enhance user experience

3.3 Personalization

Customizing your host wall experience based on your preferences and interests
Improving matching algorithms to suggest more compatible connections
Tailoring content and recommendations to your usage patterns

3.4 Safety and Security

Detecting and preventing fraudulent activity, spam, and abuse
Identifying and addressing security risks and vulnerabilities
Enforcing our Terms of Service and community guidelines
Protecting our rights, property, and safety, and that of our users

3.5 Communication

Sending important service announcements and updates
Responding to your inquiries and support requests
Providing information about account activity and security alerts

3.6 Legal Compliance

Complying with applicable laws, regulations, and legal processes
Responding to lawful requests from public authorities
Exercising our legal rights and defending against claims

4. Legal Basis for Processing (For EEA Users)

If you are located in the European Economic Area, our processing of your personal information is based on the following legal grounds:

Performance of Contract: Processing necessary to provide our Services pursuant to our Terms of Service
Consent: Processing based on your consent where we have obtained it
Legitimate Interests: Processing necessary for our legitimate interests, such as improving our Services and marketing
Legal Obligation: Processing necessary to comply with our legal obligations

We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

5.1 Service Providers

We engage third-party companies and individuals to perform services on our behalf, including cloud hosting and infrastructure providers, video and audio communication technology partners, customer support and communication platforms, and analytics and performance monitoring services. These service providers are contractually obligated to handle your data securely and only process it according to our instructions.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid legal process (e.g., subpoenas, court orders), requests from public and government authorities, or necessity to protect our rights, privacy, safety, or property.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or similar corporate event, your information may be transferred as part of our business assets, subject to appropriate confidentiality commitments.

5.4 Professional Advisors

We may share your information with professional advisors such as lawyers, bankers, auditors, and insurers where necessary for the provision of their services to us.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Our specific retention practices include:

Account Information: Retained while your account remains active. Deleted accounts are purged from our active systems within 30 days of deletion.
Communication Content: Messages and chat content are retained for 180 days after the last activity in a conversation, with archived content deleted after 1 year.
Device Information: Retained for 18 months after your last use of our Services before being anonymized.
Support Inquiries: Retained for 24 months to ensure consistent service quality.
Video Call Metadata: Retained for 30 days to improve service quality (video content is not stored by default).
Usage Data: Retained for 2 years for service improvement before being aggregated and anonymized.

7. Your Rights and Choices

You have significant control over your personal information. Depending on your location, you may have the following rights:

7.1 Right to Know About Data Sharing

You have the right to know whether your personal data is shared with third parties. We describe our sharing practices in Section 5 (How We Share Your Information). Upon request, we will provide you with: (1) whether we have shared your personal data; (2) the categories of personal data shared; (3) the categories of recipients (e.g., service providers, affiliates); and (4) the purposes of such sharing. To request this information, contact us at privacy@nigo.com with the subject line "Request to Know About Data Sharing" and include your account identifier or registered email. We will respond within 30 days.

7.2 Access and Portability

Request access to the personal information we hold about you
Receive your data in a structured, commonly used, and machine-readable format
Request transmission of your data to another controller where technically feasible

7.3 Correction and Deletion

Request correction of inaccurate or incomplete personal information
Request deletion of your personal information, subject to certain legal exceptions

7.4 Restriction and Objection

Request restriction of processing under certain circumstances
Object to processing of your personal information based on legitimate interests

7.5 Consent Management

Withdraw consent where processing is based on your consent
Opt-out of marketing communications at any time

7.6 Account Settings

Through your account settings, you can adjust profile visibility and discovery settings, manage matching preferences and interest categories, control notification preferences, enable or disable chat history preservation, and review and modify consent settings for various processing activities.

7.7 Data Sharing and Sales Opt-Out Mechanism

To protect users' right to know and control the flow of their personal data, users may opt-out of the following two types of data processing:

Data Sharing: This refers to the provision of user personal information to third parties outside of the Platform (such as partner service providers, affiliated companies, etc.) for non-marketing purposes (such as joint service provision and system technical support).
Data Sales: This refers to the transfer of user personal information to third parties for a fee for use in their independent commercial activities (such as targeted marketing and user profiling). Such activities must strictly adhere to the principle of obtaining explicit user consent, which can be withdrawn at any time.

Opt-out Procedure: Send an email to privacy@nigo.com. The subject line should be "Data Sharing/Sale Opt-out Request." The body of the email should include your name, account ID, contact information, and the specific data processing you wish to opt out of. Please also attach proof of identity (e.g., a photo of both the front and back of your ID card, marked "For Data Opt-out Request Only"). Submitted requests will be processed within three business days, and users will be notified of the results via SMS or email.

Data Usage Restrictions: Once you opt out, the platform will immediately cease sharing or selling your personal information to third parties. For data already shared with third parties and within the legal use period, the platform will require them to cease use and delete it (unless otherwise required by law).

Service Impact: Some service features rely on data sharing (such as joint membership services and cross-platform data synchronization). Opting out of these data sharing features may cause these features to malfunction. Before proceeding, please review the "Functional Impact Notice" displayed on the page or contact customer service for alternative options.

To exercise any of these rights, please contact us at privacy@nigo.com or support@nigo.com. We will respond to all legitimate requests within 30 days, though may require additional time for complex requests.

8. International Data Transfers

As a global service, your information may be transferred to, stored, and processed in countries outside your country of residence, including the United States, where data protection laws may differ from those in your jurisdiction.

We ensure appropriate safeguards for international data transfers, including:

Implementing Standard Contractual Clauses approved by the European Commission
Transferring data to countries with adequacy decisions from relevant authorities
Applying additional technical and organizational security measures

You may request more information about the specific mechanisms we use for international data transfers by contacting us at privacy@nigo.com.

9. Data Security

Data Protection Officer (DPO): Our Data Protection Officer supervises compliance with privacy laws, receives user inquiries and complaints about data privacy, and coordinates responses to data security incidents. You may contact our DPO at:

Name/Title: Data Protection Officer (Nigo)
Email: privacy@nigo.com
Subject line: "Data Protection Officer" or "DPO Inquiry"

We implement comprehensive security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include:

9.1 Technical Safeguards

End-to-end encryption for video calls and messaging content
Transport Layer Security (TLS) encryption for data in transit
Advanced Encryption Standard (AES-256) for data at rest
Regular security testing and vulnerability assessments
Secure coding practices and infrastructure hardening

9.2 Organizational Safeguards

Role-based access controls and principle of least privilege
Multi-factor authentication for administrative access
Regular security awareness training for staff
Strict confidentiality obligations for personnel
Comprehensive incident response planning

9.3 Physical Safeguards

Secure data center facilities with environmental controls
Biometric access controls and 24/7 monitoring
Redundant power and network infrastructure

Despite our efforts, no security measures are completely impenetrable. We cannot guarantee absolute security but commit to promptly investigating and notifying you of any suspected breaches affecting your information as required by applicable law.

10. Sensitive Data

Certain information you choose to provide may be classified as "special category" or "sensitive" data under various privacy laws, such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information, or sex life or sexual orientation.

We process this information only where you have explicitly chosen to provide it and in accordance with this policy. We do not use sensitive information for marketing purposes without your explicit consent.

Please consider carefully before sharing sensitive information on our platform, particularly in public areas like the host wall.

11. Children's Privacy

Our Services are strictly designed for and targeted to adults aged 18 years and older. We do not knowingly or intentionally collect, use, or disclose personal information from children under the age of 18. Our platform employs age-screening mechanisms during registration to prevent underage access, and we maintain a zero-tolerance policy regarding minor usage of our Services.

Protection Measures

Age Verification: Our registration process includes explicit age confirmation, and we may implement additional age verification technologies as they become available and reliable.
Proactive Monitoring: We utilize both automated systems and human moderation to identify and remove accounts that may belong to underage users.
Reporting Mechanisms: We provide easily accessible reporting options for users to flag suspected underage usage.

Parental Involvement

If we discover that we have inadvertently collected personal information from a child under 18 without verified parental consent, we will immediately suspend the account in question, initiate deletion of all collected personal information, notify the account email address of our actions and policies, and document the incident in our compliance records.

Parental Rights and Responsibilities

Parents or legal guardians who believe their child may have provided personal information to us without their consent should contact us immediately at privacy@nigo.com. When contacting us, please provide the child's username or account information, your relationship to the child, a description of your concern, and your contact information. Upon receiving a verifiable request, we will acknowledge receipt within 48 hours, investigate the claim promptly, provide confirmation of account deletion if underage usage is confirmed, and offer additional resources for online safety education.

Educational Resources

We recommend that parents and guardians monitor their children's online activities, use parental control tools available on devices and networks, educate children about the importance of online privacy and safety, and regularly discuss appropriate online behavior and potential risks.

12. Regional Privacy Rights

12.1 California Residents

California residents have specific rights under the California Consumer Privacy Act (CCPA), including right to know what personal information is collected, used, shared, or sold; right to delete personal information; right to opt-out of the sale or sharing of personal information; and right to non-discrimination for exercising privacy rights. To exercise your CCPA rights, please contact us with "CCPA Request" in the subject line at privacy@nigo.com.

12.2 European Economic Area Residents

EEA residents enjoy comprehensive rights under the General Data Protection Regulation (GDPR), including those outlined in Section 7 of this policy. Our legal basis for processing is detailed in Section 4.

12.3 Virginia Residents

Virginia residents have rights under the Virginia Consumer Data Protection Act (VCDPA), including rights to access, correct, delete, and obtain a copy of personal data, and to opt out of certain processing activities. Submit VCDPA requests to privacy@nigo.com with "VCDPA Request" in the subject line, including your username and proof of Virginia residency.

12.4 Other Jurisdictions

Residents of other jurisdictions with comprehensive privacy laws (such as Colorado, Connecticut, Utah, and others) may have similar rights. We will comply with all applicable privacy laws in the jurisdictions where we operate.

13. Cookies and Similar Technologies

We use cookies and similar technologies to:

Authenticate users and maintain secure sessions
Remember your preferences and settings
Analyze service performance and usage patterns
Deliver and measure the effectiveness of advertising (where applicable)

You can control cookies through your browser settings, though disabling certain cookies may affect functionality.

14. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services. This Privacy Policy does not apply to such third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you use.

15. Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of significant changes through in-app notifications or email at least 30 days before they take effect. The "Last Updated" date at the beginning of this policy indicates when it was last revised.

Your continued use of our Services after any modification to this policy constitutes your acceptance of the updated terms.

16. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Nigo Team
Email: privacy@nigo.com or support@nigo.com

Data Protection Officer (DPO): For matters related to data protection, privacy compliance, or to exercise your privacy rights, you may contact our Data Protection Officer directly:
Email: privacy@nigo.com (use subject line "Data Protection Officer" or "DPO Inquiry").

We are committed to working with you to resolve any complaints or concerns about our use of your personal information.