Komey Privacy Policy

Last Updated: February 23, 2026

Effective Date: February 23, 2026

1. Introduction

This Privacy Policy ("Policy") explains how Komey ("we", "us", "our") collects, uses, stores, discloses, and protects personal information of users ("you", "your") of the Komey mobile application (the "App"). This Policy applies to all users of the App worldwide, excluding the People's Republic of China. By accessing or using the App (including making in-app purchases), you confirm that you are 18 years of age or older and consent to the collection and use of your information as described in this Policy.

We adhere to applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA), United Kingdom, and Switzerland.

2. Information We Collect

2.1 Personal Information

Account Information: When creating an account, we may collect your email address, username, profile photo, and other voluntary profile information you provide.
Usage Data: We collect data about your interactions with the App, including features used, content viewed, session duration, device information (model, OS version, unique device identifiers), IP address, and approximate location (based on IP address, with your consent).
User-Generated Content (UGC): Any content you post, upload, share, or transmit through the App (including text, photos, videos, audio, comments, and messages) is collected and stored to provide the App's core functionality.
Payment-Related Data: For in-app purchases (IAP), we collect transaction identifiers, purchase dates, and product information provided by Apple Inc. (via the App Store). We DO NOT collect, store, or process your payment card details, CVV, or billing address – all payment processing is handled exclusively by Apple.
Communication Data: If you contact our support team (including IAP-related inquiries), we collect your communication content (e.g., emails, chat messages) to respond to your inquiries.

2.2 Non-Personal Information

We collect anonymous, aggregated data that does not identify you individually, such as app usage statistics, demographic trends, feature engagement metrics, and IAP purchase patterns. This data is used solely to improve the App's performance and user experience.

3. Use of Collected Information

We use your information for the following legitimate purposes:

To provide, maintain, and improve the App's core functionality (including IAP features) and user experience.
To process, verify, and fulfill in-app purchase transactions (using Apple-provided transaction data).
To moderate, review, and manage User-Generated Content (UGC) in compliance with our Content Policies.
To communicate with you about App updates, security notices, support responses, purchase confirmations, refund status, and important policy changes.
To enforce our Terms of Service and this Privacy Policy, including investigating and addressing violations (including IAP fraud).
To comply with legal obligations, respond to lawful requests, and protect our rights, privacy, safety, or property (and that of our users and the public).
To personalize your App experience (e.g., content/IAP recommendations) with your explicit consent.

4. User-Generated Content (UGC) Policy

You retain ownership of all UGC you submit to the App, but you grant us a non-exclusive, worldwide, royalty-free, transferable license to use, reproduce, modify, display, distribute, and store such content to operate, maintain, and improve the App. We reserve the right to moderate, remove, or disable access to any UGC that violates this Policy, without prior notice.

4.1 Prohibited UGC Content

You are strictly prohibited from posting, uploading, sharing, or transmitting any UGC that contains, promotes, or facilitates:

Adult/Obscene Content: Pornography, sexually explicit material, non-consensual sexual content, nudity (except for non-sexual, artistic, or educational purposes), or content depicting sexual acts, exploitation, or lewd behavior.
Offensive/Discomforting Content: Graphic violence, gore, self-harm, suicide, hate speech, harassment, bullying, or any content that causes severe emotional distress, fear, or discomfort to other users.
Gambling-Related Content: Illegal gambling, online betting, lottery schemes, sports wagering, casino-style games for real money, or any form of financial wagering that violates applicable local laws.
Drug-Related Content: Promotion, sale, distribution, or use of illegal drugs, controlled substances, drug paraphernalia, or instructions for manufacturing illegal narcotics or psychoactive substances.
Political Content: Content that promotes political extremism, election interference, violence against political figures/groups, hate towards political parties, or content that incites political unrest, rebellion, or violations of local political regulations.
Discriminatory Content: Content that promotes or incites discrimination, prejudice, or hatred based on race, ethnicity, national origin, gender, gender identity, sexual orientation, religion, disability, age, socioeconomic status, or any other protected characteristic under applicable law.
Illegal Activities: Content that facilitates theft, fraud, hacking, terrorism, human trafficking, or any other criminal act (including IAP fraud, refund scams, or unauthorized sharing of paid content).
Infringing Content: Copyrighted material, trademarks, trade secrets, or intellectual property of third parties without explicit authorization from the rights holder (including paid IAP content).
Impersonation: Content that falsely represents another person, entity, or organization (including Komey or Apple) for deceptive purposes (e.g., fake IAP offers).

4.2 UGC Moderation and Enforcement

We use a combination of automated content moderation tools and human reviewers to monitor UGC for compliance with this Policy. We may:

Remove or disable access to prohibited UGC at any time, without notice;
Suspend or terminate your account (including revoking access to purchased IAP content) for repeated or severe UGC violations;
Report illegal UGC to relevant law enforcement authorities when required by law;
Preserve UGC evidence of violations to defend our legal rights or comply with legal requests.

5. GDPR Compliance (EEA/UK/Switzerland Users)

For users in the EEA, UK, or Switzerland, you have the following rights under the GDPR:

Right to Access: Request a copy of all personal information we hold about you (including UGC metadata and IAP transaction data).
Right to Rectification: Request correction of inaccurate, incomplete, or outdated personal information.
Right to Erasure ("Right to be Forgotten"): Request deletion of your personal information, subject to legal obligations (e.g., retaining IAP transaction data for tax/accounting purposes). Note: Deletion may revoke access to purchased IAP content as required by Apple's terms.
Right to Restriction of Processing: Request that we limit the processing of your personal information (e.g., stop using it for IAP recommendations).
Right to Data Portability: Request a copy of your personal information (excluding payment data, which is held by Apple) in a machine-readable format for transfer to another service provider.
Right to Object: Object to the processing of your personal information for marketing, profiling, or non-essential purposes (including personalized IAP recommendations).
Right to Withdraw Consent: Withdraw your consent to data processing (where processing is based on consent) at any time, without affecting the lawfulness of processing before withdrawal.

To exercise these rights, contact us at support@komylogic.com. We will respond to valid requests within one month (or up to three months for complex requests, with written notice).

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for commercial purposes. We may share your information in the following limited circumstances:

With trusted service providers who assist us in operating the App (e.g., cloud storage, analytics, customer support, IAP processing), subject to strict confidentiality agreements that prohibit them from using your information for any other purpose.
With Apple Inc. to process in-app purchase transactions, verify refunds, and comply with App Store Review Guidelines (in accordance with Apple's privacy policy).
To comply with legal obligations, court orders, subpoenas, or lawful requests from government authorities.
To protect our rights, privacy, safety, or property (and that of our users and the public), including investigating fraud, security breaches, or IAP refund abuse.
In the event of a merger, acquisition, or sale of all/part of our assets: your information (including IAP history) may be transferred to the acquiring entity (we will notify you of such transfer where required by law).

7. Data Security

We implement industry-standard security measures to protect your personal information (including IAP transaction data) from unauthorized access, disclosure, alteration, or destruction, including:

Encryption of data in transit (HTTPS) and at rest (AES-256);
Access controls and authentication mechanisms for our internal systems;
Regular security audits and vulnerability assessments;
Employee training on data protection and privacy best practices;
Isolation of IAP transaction data from other user data to minimize risk.

While we take reasonable precautions, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security of your information.

8. 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:

Account information: Retained until you delete your account (or 12 months after inactivity, whichever comes first).
UGC: Retained until you delete it or until we remove it for policy violations (we may retain copies of violating UGC for up to 2 years to comply with legal obligations).
IAP transaction data: Retained for 7 years to comply with tax, accounting, and legal obligations (e.g., processing refunds, resolving disputes).
Support communication data: Retained for 2 years to resolve disputes and improve support services (including IAP-related inquiries).
Usage data: Anonymized and retained indefinitely for analytics and App improvement.

When personal information is no longer needed, we securely delete or anonymize it to prevent identification.

9. Third-Party Services

The App may contain links to third-party websites or integrate with third-party services (e.g., social media platforms). We are not responsible for the privacy practices or content of these third parties. We encourage you to review the privacy policies of any third-party services you access through the App.

In-app purchases are processed exclusively through Apple's App Store, and Apple's privacy policy applies to all payment data processing. We have no access to your Apple ID, payment card details, or billing information.

10. Key Notices

This App offers in-app purchases (IAP) for premium features, digital content, subscriptions, or virtual goods. All IAP transactions are governed by Apple's App Store Terms of Service.
We do not knowingly collect personal information from individuals under 18 years of age, nor do we process IAP transactions for users under 18 (in compliance with Apple's terms). If we become aware that we have collected such information, we will delete it promptly.
This Policy applies only to users outside of the People's Republic of China. Separate privacy policies apply to users in China (not covered herein).
All IAP refunds are processed in accordance with Apple's refund policy – we do not control or process refund requests directly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements (including IAP-related changes). We will notify you of material changes by:

Posting the updated Policy on the App with a prominent notice;
Sending an email notification to your registered email address;
Displaying a pop-up notice within the App (for major changes, including IAP policy updates).

Updated Policies will take effect 30 days after notification, unless required otherwise by law. Your continued use of the App (including making IAPs) after the effective date constitutes acceptance of the updated Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, our data practices, UGC moderation, or in-app purchase privacy, please contact us at:

Email: support@komylogic.com