Privacy Policy

Last updated: May 26, 2025

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Welcome to Chatter! This Privacy Policy explains how Chatter Social Inc. (“Chatter”, “we”, “us” or “our”), located at 10411 Motor City Dr #350, Bethesda, MD 20817 (USA), collects, uses, stores, and shares your personal information when you use the Chatter social media platform, mobile application, and related services (collectively, the “Services”). Chatter is a real-time, group-first, interest-based social platform with features including Live Rooms (audio/video streaming), Replays, Moments, threaded posts, group chats, subscriptions, RocketChats, ticketed events, and AI-powered personalization tools such as Luna and AI Avatars. We are committed to protecting your privacy and complying with all applicable laws, including the EU GDPR, UK data protection laws, CCPA/CPRA (California), LGPD (Brazil), and other global privacy regulations.

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By using Chatter, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Services. You must be at least 12 years old to use Chatter (older if required by your country’s laws). We do not knowingly allow children under 12 to use Chatter, and we do not knowingly collect personal data from them.

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Information We Collect

We collect personal information (also called personal data) in several ways: (a) information you provide to us directly, (b) information we collect automatically when you use Chatter, and (c) information from third parties. The types of information we collect are detailed below.

a. Information You Provide

Account Registration Information: When you create a Chatter account, we ask for basic details such as your name, username, password, email address, and/or phone number. This is required to register and secure your account.
Profile and Content: You may choose to add a profile photo, biography, interests, and other details to your profile. We also collect the content you create, upload, or share on Chatter. This includes posts and threaded comments, audio or video you stream in Live Rooms, transcripts or recordings of rooms (e.g. when Replays are enabled), images or videos you share in Moments, and messages or media you send in group chats or RocketChats. If you use our AI Avatar feature, we will collect any photos or images you upload for the purpose of generating your avatars.
Interactions and Social Data: If you participate in communities or Live Rooms, we collect information about your participation (for example, which rooms or groups you join, whether you spoke or reacted, etc.). If you subscribe to other users or content (or if others subscribe to you), we collect that information as well. We also record your preferences and settings (e.g. language preference, notification settings) so we can honor them.
Payment and Financial Information: Chatter enables ticketed events, purchases, and user subscriptions, so you may provide payment-related information. When you make a purchase or payment through Chatter, we (or our payment processor) collect information such as your payment method (e.g. credit card type, last four digits, expiration), billing address, and transaction details. For security, Chatter does not store full credit card numbers; we rely on third-party payment processors to handle sensitive financial data. If you are a content creator earning money (user monetization), we may collect additional information needed to remit payments to you, such as your Stripe, Paypal or bank account details, tax identification number, or other required payout information.
Customer Support and Communications: If you contact us for support or participate in surveys, promotions, or beta programs, we will collect the information you choose to share with us (such as your contact details and a description of the issue or feedback). We may also collect information if you participate in any research, user testing, or provide feedback through our AI assistant “Luna.”

Sensitive Information: In general, we do not require you to provide any sensitive personal data (e.g. government IDs, health or biometric data) to use Chatter. If you choose to use optional features that involve sensitive data (for example, uploading your photos for AI Avatars which could reveal biometric data like your facial image), we will handle that data with special care and only use it for the feature you requested. We will ask for your explicit consent where required by law before processing sensitive personal information.

b. Information We Collect Automatically

When you use Chatter, we automatically collect certain information about your device and activity. This includes:

Usage Data: We gather information about how you use our Services. For example, we log when you login and logout, which features or communities you interact with, content you view or engage with (likes, comments, shares), Live Rooms or events you join, and other actions. We also collect data on how you scroll, click, or otherwise interact with the app’s interface to understand engagement and improve the user experience. We may collect information on links or Chatter content you interact with, including in emails or notifications we send you.
Device and Technical Information: We collect data from and about the device(s) you use to access Chatter. This includes your device type, operating system version, browser type (if using web), app version, device identifiers, mobile network, and IP address. For example, we may record your IP address and infer your approximate location from it (such as city or country level) to customize content (e.g., showing you relevant posts or suggestions trending in your region) and for safety and fraud prevention. We also collect device event information like crashes, system activity, and hardware settings to maintain service quality.
Cookies and Similar Technologies: Like most online services, we and our partners use cookies, pixels, and similar tracking technologies on our website and possibly within the app. Cookies are small data files stored on your browser or device. These technologies help us recognize you, remember your preferences, and understand usage of our Services. For instance, they enable features like staying logged in, and help us analyze traffic and feature usage patterns. We also use them to personalize your experience (for example, to keep track of content you’ve seen or to suggest new groups). You can control cookies through your browser settings and other tools, however note that removing or rejecting cookies may affect the availability and functionality of some features. (For more details, see Cookies & Tracking Choices below.)
Audio/Video Data: If you participate in a Live Room with audio and/or video enabled, we may process your voice and video stream in real time to deliver it to other participants. If the Live Room host enables Replays (recording), the audio/video and transcripts of that room will be recorded and stored by us, and made available to others per the host’s settings. We may also temporarily record live audio (even if Replays are off) for moderation purposes – for example, to investigate reports of abuse in real-time rooms – and then delete those recordings if no issue is reported. (See How We Use Information – Safety and Moderation below for more details.)
Location Services (Optional): Chatter may offer features that use precise location data – for example, tagging your posts with a location, or finding local events. We will ask your permission before accessing precise GPS location from your device. If you grant permission, we will collect and use that precise location data for the specific feature, but you can disable it at any time in your device settings. Even if you don’t share GPS data, as noted above, we may still infer an approximate location from your IP address for basic service functionality.

c. Information from Third Parties

We may receive information about you from third-party sources in the following scenarios:

Third-Party Account Integrations: Chatter allows integration with certain third-party services for enhanced functionality. For example, you may have the option to sign up or log in via third-party accounts like Google, Apple, or Bluesky. If you do so, we will receive information from that third party such as your name, email address, user ID and any other information you authorize the third party to share with us (the specific data will be disclosed to you when you connect). We use this information to simplify account creation and verify your identity. Similarly, if you connect your Chatter account to other services – for instance, linking to your Bluesky profile or using our multistreaming feature to broadcast a Live Room to another platform – we will receive and/or share information as needed to enable those features. For example, if you choose to multistream a Chatter Live Room to an external platform, we will transmit the audio/video content of that stream to the third-party service at your direction. If you connect an account like Bluesky to import or cross-post content, we will access and process information from that account (such as your posts or contacts on that service) only with your consent and as necessary to provide the integration. You can disconnect third-party accounts from Chatter at any time via your settings.
Payment Processors and App Stores: If you purchase a subscription or ticket through an app store (e.g. Apple App Store or Google Play) or a payment processor like Stripe, those third parties will collect and process your payment information. We may receive some limited information from them confirming the transaction or subscription status (such as a confirmation of payment, your subscription term, or an updated email address or contact method). We use this information to fulfill your purchase and maintain your subscriptions. Chatter itself does not receive or store your full financial account numbers from these transactions, aside from what you provide (as described in “Information You Provide – Payment Information”).
Other Users: Chatter is a social platform, so information about you can be generated by other users. For example, other users may mention or tag you in posts or comments, or send you direct messages (group chats). If another user invites you to join Chatter or a specific community, they might provide your email or phone number (with your consent) to send an invitation. In such cases, we will process that contact information to send the invitation, but will not use it for other purposes unless you join Chatter. Additionally, content that other users share about you (such as a photo of you in a group) is their responsibility. If you believe another user is infringing on your privacy or misusing your information, you can report it to us for review.
Public Sources: We may collect information that is publicly available about you. For example, if your profile is public on Chatter or you publicly post content, it can be viewed by anyone including us. We might also glean publicly available information from outside sources (for example, public social media profiles or web information) to help personalize your experience or to train our AI models, as long as it is lawful to do so. For instance, if Chatter implements a feature to verify influencers or provide news updates, we might use publicly available profile data for those purposes.
Advertising and Analytics Partners: We may receive aggregated audience insights from third-party analytics firms or advertising partners to understand how users find and use our service. For example, if we run a marketing campaign on another platform, we might receive info about how many people installed Chatter as a result. These third-party insights, however, do not identify you personally; they are used to measure and improve our marketing efforts. If we ever directly receive personal data about you from a third-party ad partner for targeted advertising, we will do so only if we have ensured appropriate legal basis (e.g., consent) and transparency to you. (Currently, Chatter’s monetization is focused on user subscriptions and events, and we do not serve third-party ads in the app; see “Sharing – No Sale of Personal Data” below.)

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How We Use Your Information

We use the collected information for the following business and operational purposes, in accordance with applicable legal bases (such as your consent, our legitimate interests in operating a safe and efficient service, and/or performing a contract with you to provide the Services):

Provide and Maintain the Service: First and foremost, we use your information to operate Chatter and provide you with the features and services you expect. This includes using your data to create and manage your account, display your profile, deliver the content and communications you request (e.g. showing posts in your feed, streaming your voice in a Live Room to other participants, delivering your chat messages to recipients), and enabling interactions like comments and reactions. We use your information to process transactions you initiate (e.g. confirming a ticket purchase or subscription and giving you access to paid content). Essentially, we use your data to fulfill our contract with you – to let you use Chatter’s features as intended.
Personalize and Improve Your Experience: We want Chatter to be engaging and relevant to you. We therefore use the information we collect to personalize the content you see and the recommendations we make. For example, we analyze your activity (communities you join, topics you engage with, people you interact with) to suggest new groups, Live Rooms, or content you might enjoy. Our AI personalization tool “Luna” utilizes your usage data to tailor content and community suggestions in real-time. We also use machine learning to curate Moments (highlights from content you may have missed) and to customize what appears in your feed or notifications. Additionally, we may use the information we collect (along with publicly available information) to help train and improve our machine learning and AI models that power personalization and other features. This training helps us refine our algorithms to better serve relevant content and make Chatter more intuitive. (For example, training an AI model on conversational data might improve Luna’s ability to suggest interesting rooms.) All such processing is done in accordance with applicable data protection laws, and where required, we will seek your consent for certain types of personalization.
Enable New and Optional Features: Your information allows us to offer innovative features. For instance, if you choose to use the AI Avatar feature, we will use the photos you provide to generate your avatars using AI algorithms. We use your images solely to create the avatars and to improve that feature (we may internally analyze how well the AI performed, etc.), and we delete or highly secure any raw images after processing to protect your privacy. Similarly, if you integrate or cross-post with third-party services (like Bluesky or other platforms), we use your data to facilitate those cross-service features. For example, we might use tokens from your linked account to fetch your posts from another network or to post your Chatter content there. We also use your info to facilitate user discovery features, such as helping others find you on Chatter if you both know each other (we will only do this based on information you have provided or consented to share, such as mutual contacts or synced address book data—if we ever offer contact syncing). In summary, whatever new feature we roll out, we will use your information only as necessary to provide that feature and, in a manner consistent with this Privacy Policy.
Communicate with You: We use contact information (like your email and in-app notifications) to send you service-related communications and updates. These include confirmation messages (e.g., account verification, purchase receipts), administrative alerts (such as important security or privacy notices), and communications about changes to our terms or policies. If you’re open to it, we may also send you marketing messages to tell you about new features, events, or promotions on Chatter that might interest you. You can opt out of marketing emails at any time by clicking the “unsubscribe” link in them or adjusting your notification settings. (Transactional and policy communications, however, may be necessary to send even if you opt out of marketing.) We may also respond to your inquiries or support requests using your information.
Safety, Security, and Moderation: Keeping Chatter a safe and trustworthy community is a top priority. We use information for safety and integrity measures, including detecting, investigating, and preventing fraud, spam, abuse, and other harmful or illegal activities on the platform. For example, we may monitor public content and communications for violations of our Community Guidelines, and we use automated systems and moderators to flag misconduct (such as hate speech or harassment) and take appropriate action. We verify accounts and detect bots by analyzing account information and behavior. We may use your information to authenticate your identity (for instance, using your email or phone for two-factor authentication or to verify your age, if we suspect underage use). We also may record or monitor Live Room conversations temporarily for moderation purposes when a complaint is received, as described earlier, and to ensure user safety. Such recordings are retained only as long as needed to investigate the issue. Additionally, we use data to enforce our Terms of Service and user agreements, which may include using information to ban accounts that violate rules and to keep records of those violations. (For example, if an account is suspended for severe misconduct, we might retain certain identifiers to prevent the wrongdoer from simply creating a new account under a different identity.) Using your data in these ways helps us protect the platform and our users from bad actors and maintain the integrity of our community.
Analytics, Performance, and Development: We internally analyze how users use Chatter in order to troubleshoot errors, test features, and improve the overall performance of our Services. This means we might use your data to debug software (for example, investigating a crash report tied to certain device information), to measure the effectiveness of new interface changes, or to gather aggregate insights on what features are most popular. We also use data (often in aggregated or pseudonymized form) for research and development of new products or services. For example, understanding which features users engage with helps us decide what to build next. We may also use your information to measure the effectiveness of any advertising or promotional campaigns (if we ever run Chatter ads on other platforms, for instance, we’d analyze referral data). Overall, these uses help us make Chatter better and more useful for our user base.
Legal and Compliance: We may use your personal information to comply with legal obligations to which we are subject. This includes using data to respond to lawful requests from public authorities (e.g. subpoenas or court orders), to meet legal reporting requirements, or to enforce legal rights. We also use information to ensure we are complying with applicable laws (for instance, export regulations or sanctions lists, ensuring we’re not providing services to prohibited parties). Additionally, if you exercise your privacy rights (such as requesting access or deletion), we will use your information to fulfill those requests and log our compliance.

Legal Bases for Processing (for Users in the EU/EEA, UK, Brazil, etc.): When we process your personal data, we rely on certain legal grounds, such as: your consent (e.g., for sending marketing emails or processing optional sensitive data like photos for avatars), contract necessity (we need the data to provide the Services you’ve requested), legitimate interests (for example, to ensure security, improve our product, and show you relevant content – we balance these interests against your privacy rights), and legal obligation (where we have to comply with laws). If you have questions about the legal basis of specific processing activities, you can contact us (see Contact Us at the end). And importantly, we do not sell your personal information to third parties, as explained in the Sharing section below.

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How We Share Your Information

We understand that sharing of personal information with third parties can impact your privacy. Chatter does not sell your personal data to data brokers or other third parties for profit. We only share information in the following circumstances:

With Other Chatter Users (Social Sharing): Chatter is designed for communication and content sharing, so any information you post or send on the platform may be seen by others, depending on the privacy settings of the feature you are using. For example, posts in a public community or Moments you create are visible to all Chatter users (and potentially indexable by search engines if we enable a web view for that content). Posts in a private group are visible to members of that group. If you speak in a Live Room or appear on video, other participants will hear/see you, and if that room has Replays enabled, the recording of your voice/image will be available to others later as part of the Replay. Group chats and RocketChats are generally only visible to the participants of those chats, but keep in mind participants could screenshot or copy messages. In summary, information you share intentionally on Chatter (including your profile information, public posts, and any content in open forums) will be accessible to those you expect – either the general public or the members of the intended group. Chatter cannot control (and is not responsible for) how other users may use or re-share your information. So please be mindful of your own privacy needs when choosing what to share publicly.
With Your Consent or At Your Direction: We will share your information with third parties when you explicitly ask or consent for us to do so. For instance, if you link Chatter with a third-party app and authorize us to share information (such as posting your Chatter content to another service), we will do so. If you purchase a ticket to an event organized by a third-party through Chatter, we may share your name or contact info with the event organizer if needed to administer the event – but we’ll do so only with your knowledge (for example, it will be evident because you are signing up for that specific event). Outside of such scenarios, we will ask for your consent before sharing your personal data with an outside party for their own purposes.
Service Providers (Processors): We employ trusted third-party companies and individuals to help us provide the Services on our behalf. These include, for example, cloud hosting providers, data storage services, content delivery networks, analytics providers, customer support tools, email/SMS delivery services, payment processors, and AI service providers (for features like Luna’s AI or avatar generation). These third parties process your information only under our direction and for the purposes of operating Chatter (not for their own use). We contractually require service providers to protect your data with appropriate security measures and to comply with applicable privacy laws. For example, we may use cloud infrastructure to host our databases (which means your data is stored on their servers), or we might use a service to transcribe audio to text for accessibility features – in all cases, our service providers are bound to strict confidentiality and data protection obligations. We only share the information that the provider needs to perform their specific services for us.
Other Online Services You Connect: When you choose to connect Chatter to other online services, we share information with those services as needed to make the integration work. For example, if you integrate your Chatter account with Bluesky (a third-party social network) to find friends or share content between platforms, we may share your basic account info and relevant content to the extent you authorize. If you use multistreaming, we share the stream content to the platforms you select. Likewise, if you share a link from Chatter to an external platform (like posting a Chatter Moment to Twitter), the preview or content you share will be accessible to whatever audience you choose on that platform. Please note that any information shared with an external service is subject to that service’s own privacy policy, not this one. We encourage you to review the privacy settings and policies of any third-party services you connect with Chatter.
Business Partners & Marketing: We may share some information with partners who help us promote Chatter or who provide ancillary services. For example, we might allow a partner to offer a joint event or promotion, and if you choose to participate, we would share the necessary data (like your name or user ID to verify eligibility). We might also share aggregated, non-identifying information with business partners for business or research purposes – for instance, telling a potential advertiser or investor generalized statistics like “Chatter has X million monthly active users interested in topic Y” without revealing personal identities. If we ever engage in cross-promotional activities (like referring you to a creator’s paid content on another platform), we will do so transparently. In some cases, we use marketing service providers or platforms (like an email marketing service to send newsletters or a social media platform to advertise our app). Those providers may receive limited data as needed (e.g. your email address for sending our newsletter, or a device identifier hashed for ad targeting). We ensure such sharing complies with applicable law (for instance, we would obtain opt-in consent if required). Importantly, even when we work with marketing partners, we do not “sell” your personal information for money; any sharing is only to provide or promote our own Services as described.
Legal Compliance and Protection: We may preserve, use, or disclose your information if we believe it is reasonably necessary to comply with a law, regulation, legal process, or governmental request. This includes responding to court orders, subpoenas, or lawful requests by public authorities (for example, to meet national security or law enforcement requirements). We may also disclose information to protect the rights, property, or safety of any person – including our users, third parties, or Chatter itself. For example, if needed we might provide information to law enforcement to help prevent or investigate illegal activities, or to regulators if required as part of a legal inquiry. We may also share data to enforce our terms and policies, to address fraud, security, or technical issues (such as sharing data with security consultants to investigate a breach), or to prevent spam, abuse, or malicious actors on our Services. In short, if we in good faith believe disclosure is required or permitted by law, we may do so, but we will always consider your privacy rights and aim to minimize such sharing.
Corporate Transactions: If Chatter Social Inc. is involved in a potential or actual merger, acquisition, investor funding, reorganization, bankruptcy, or sale of assets, your information may be transferred to or shared with the parties involved in the transaction as part of due diligence or the execution of the deal. For example, if another company acquires Chatter, user information would likely be one of the assets transferred to that company. In such cases, we will require that your personal data remains subject to protections consistent with this Privacy Policy. We will also provide notice to users (for example, via email or an in-app notification) if your personal information will be transferred and become subject to a different privacy policy. The new entity will continue to honor any pre-existing privacy commitments made to you in this Policy, unless you consent otherwise.
Affiliates: We currently operate Chatter as a single company. If in the future Chatter Social Inc. has affiliates, subsidiaries, or related companies, we may share your information among our corporate family as needed to operate and improve the Services. For example, if we establish an affiliate in another country to help with user support or data analytics, we might transfer relevant data to them. Any such affiliate will follow practices at least as protective as those described here.
Aggregate or De-Identified Data: We may share information that has been aggregated (combined with information about other users so it no longer is linked to a specific person) or de-identified/anonymized (stripped of personal identifiers). This information cannot reasonably be used to identify you. We may disclose such non-personal data publicly and to third parties – for example, publishing trends about content usage, or sharing anonymized analytics with business partners. These reports will not contain any information that could be used to identify any individual user.

No Sale of Personal Information: Chatter does not sell or rent your personal information to third parties for their own marketing or advertising purposes. We also do not share your personal information with third parties for cross-context behavioral advertising without the appropriate notice and opt-out (as required by laws like the CPRA). In California terms, we have not “sold” or “shared” personal information of users we know to be under 16, and we do not sell personal info of any users in the conventional sense. If this ever changes, we will update this policy and provide required opt-out mechanisms.

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Cookies & Tracking Choices

Cookies and Online Analytics: As noted, Chatter and our service providers use cookies and similar technologies to provide and improve the Services. For example, our website may use Google Analytics or other tools that set cookies to collect usage data and report website trends. These analytics services may collect information such as your IP address, web browser, pages viewed, time spent, and links clicked. We use this analytics information to understand web traffic and improve our site. We also may implement local storage or SDKs in our mobile app for similar purposes (to store preferences or track usage events).

Your Choices: You have the following options to control or limit how we and third parties use cookies and tracking:

Browser Settings: For web usage, you can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. You can also usually clear existing cookies through your browser. Each browser’s help or settings should explain how to manage cookies. Keep in mind that disabling cookies may affect site functionality (for instance, you might have to log in repeatedly, or certain features might not work).
Analytics Opt-Out: Google Analytics provides an opt-out mechanism (a browser add-on) if you don’t want your site activity to be available to it. Other analytics providers may offer similar opt-outs. We honor such choices in accordance with their tools.
Mobile Ad ID Opt-Out: If we ever use mobile advertising or analytics that leverage your device’s advertising ID, both iOS and Android allow you to reset your mobile identifiers or limit ad tracking via your device settings. You can enable settings like “Limit Ad Tracking” (on iOS) or “Opt out of Ads Personalization” (Android) which inform companies not to use your app usage data for targeted advertising.
Do Not Track: “Do Not Track” (DNT) is a setting in some browsers that you can turn on to signal a preference not to be tracked across websites. Currently, there is no standard interpretation of DNT signals. As a result, like many websites, our website does not respond to Do Not Track signals at this time. However, we continue to monitor industry and legal developments around DNT.
Global Privacy Control: Global Privacy Control (GPC) is a browser setting or extension that can send a “do not sell or share” signal to websites for California residents. If our site detects a GPC signal, we will treat it as a valid request to opt out of the sale/sharing of personal information associated with that browser, as required by California law. Since we do not currently sell personal data, this mainly would apply if we were using third-party targeted advertising cookies, which we presently do not.

For more information about cookies and how to manage them, you can visit resources like aboutads.info or youronlinechoices.eu (which offer guidance on opting out of data collection for interest-based advertising).

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International Data Transfers

Chatter is a global service – we have users all around the world – and our technical infrastructure is primarily located in the United States. This means that your personal information may be transferred to, stored in, and processed in the United States or other countries outside of your home country. For example, if you are in the European Union or Brazil, your data will likely be processed in the U.S. (where our company and main servers are based) as well as possibly in other jurisdictions where our service providers maintain facilities. By using our Services, you understand and acknowledge that your information will be transmitted across national borders to where Chatter and its service providers operate.

However, we take steps to ensure that international transfers of personal data are handled in a lawful manner that provides adequate protection. In particular, when we transfer personal data from regions like the European Economic Area (EEA), United Kingdom, or Brazil to the United States or other countries that may not have equivalent privacy laws, we rely on appropriate legal safeguards:

Standard Contractual Clauses: We implement the European Commission’s approved Standard Contractual Clauses (SCCs) (and equivalent mechanisms under UK and Swiss law) for data transfers where applicable. These are contractual commitments between companies transferring personal data, binding them to protect the data in line with EU privacy standards. Our contracts with data processors (like cloud providers) include SCCs as needed, obligating them to safeguard your information.
Additional Safeguards: In addition to SCCs, we may apply additional technical and organizational safeguards, such as encryption of data in transit and at rest, robust access controls, and auditing processes to protect data when it’s transferred internationally. We also carefully review the privacy practices and data protection standards of any third-party partners in other countries to ensure they meet our requirements. If data will be shared onward to further third parties, we contractually require them to provide an equivalent level of protection.
Data Privacy Framework (if applicable): (Note: As of the last update of this Policy, Chatter is evaluating participation in the EU-U.S. Data Privacy Framework (DPF) program.) If we become certified under a recognized transfer framework (such as the DPF or any future adequacy framework between other regions and the U.S.), we will update this policy to reflect that and ensure compliance with the framework’s principles.
Your Consent in Certain Cases: In the absence of other safeguards, we may ask for your explicit consent to transfer your personal data to a jurisdiction which may not provide the same level of data protection as your home country. For example, if a particular optional feature requires sending data to a third party in a country without an adequacy decision or other safeguard, we will inform you and obtain your consent as needed. You always have the right to withdraw such consent.

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We understand that privacy laws in some countries (like in Europe and Brazil) require that individuals have rights and effective legal remedies when their data is transferred abroad. Rest assured, no matter where your data is processed, we will apply the same protections described in this Policy. If you have questions about our international data practices, or if you need more information about the specific safeguards we use, you can contact us (see Contact Us section). We can provide additional details or a copy of the relevant contractual protections upon request.

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Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. How long we keep data depends on the type of information and the context in which it’s used:

Account Information: We retain the personal information associated with your account (such as your profile info, email, login credentials, etc.) for as long as your account is active. This is necessary to provide you with the Service. If you decide to delete your account, we will initiate deletion of this information from our systems, subject to the grace period and exceptions below.
User-Generated Content: Content you post (such as comments, posts, Moments) and data about your activities (like your interactions or participation in rooms) typically remain on our Services until you remove them or delete your account. If you delete a specific piece of content (for example, you delete a post or a message), we will make reasonable efforts to remove it from user-facing display and our active databases. However, cached or backup copies might persist temporarily. Also, content that was publicly visible or shared with others may still be independently retained by those third parties (for example, another user might have saved or re-shared something you posted). We do not control such external retention.
Live Room Recordings (Replays): If a Live Room is recorded as a Replay, we store that recording until it is deleted by the room host or by us according to our retention policy. As a host, if you enable a Replay, you can delete the Replay recording at any time, which will remove it from our platform (though again, any users who downloaded or copied it during its availability would still have their copies). If not deleted, Replays may remain available indefinitely, or for the duration we specify (we will let users know if Replays auto-expire after a certain time in future updates of our features).
Transactional Data: If you conduct financial transactions on Chatter (like buying tickets or earning subscription revenue), we will retain records of those transactions for as long as required by law (for example, for tax and accounting purposes) and as needed for any dispute resolution. Even if you delete your account, we may be required to keep certain payment records. We only keep what is necessary and will handle it per this Policy. For instance, records of payments and purchases may be kept for several years as mandated by financial regulations.
Communication Data: If you contact customer support or otherwise communicate with us (e.g., via email, Luna or feedback forms), we may retain those communications and any attached information for a period of time. This helps us manage your current and any future inquiries. Typically, such records are kept for the time needed to resolve your request and for a reasonable period after (for example, up to 18 months for routine support communications). We might retain them longer if needed to establish, exercise, or defend legal claims.
Logs and Analytics: Our server logs, analytics records, and backups are generally purged or anonymized on a regular schedule. For example, raw logs of IP addresses may be kept for a short period (such as a few months) for security analysis and then either deleted or stored only in aggregate form. Analytics data may be retained longer in aggregate form for trend analysis, but not in a way that identifies individuals.
Legal Holds and Obligations: We might need to retain certain information for longer periods if required by law or if the data is subject to an investigation or legal hold. For instance, if we receive a legal subpoena for certain data, or if data needs to be preserved as evidence for a legal claim, we will retain that data to comply with the law. Also, if you exercise a privacy right like objecting to processing or requesting restriction of processing, we might keep a record of that request to honor it going forward.
Deleted Accounts: When you delete your Chatter account (or request deletion), we follow a process to deactivate and then delete your personal data. First, your account will be deactivated (and no longer visible to other users). We retain the deactivated account data for a short grace period (typically about 30 days) in case you change your mind or the deletion was accidental. During this period, you can contact us to reactivate your account. After the grace period, we will begin the process of permanently deleting your personal data from our systems. Complete deletion (from all backups, etc.) may take additional time, but generally occurs within 60-90 days of the deletion request. Certain information that is not stored in user-specific accounts (e.g., log records tied to device IDs in backups) might take longer to purge, but we will either delete or anonymize such data.
Retention for Safety: As mentioned under Safety uses, if an account is terminated or suspended for harmful conduct, we may retain certain data (like banned accounts list, device identifiers or hashed fingerprints) indefinitely to block the user from re-registering and to protect our community. This data is limited to what’s necessary for this purpose and is not used for other purposes.

After we no longer need personal information for the purposes described above, we will either delete it or anonymize it (so that it can no longer be associated with you). If it’s not feasible (for technical or legal reasons) to completely delete the data, we will ensure that appropriate measures are in place to prevent any further use of the data.

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Your Rights and Choices

You have rights and choices regarding your personal information. We strive to provide the same core privacy protections to all our users worldwide. However, your specific rights may vary based on the laws that apply to you (for example, users in the European Union, United Kingdom, Brazil, California, and other regions have specific legal rights regarding personal data). Below, we outline the general rights you have and how to exercise them:

Access Your Information: You have the right to know what personal information we have collected about you, and to request access to that data. This includes the right to ask for a copy of the personal data we hold about you in a common electronic format. How to Access: Many pieces of information are available directly in your account. For example, you can view or edit your profile information at any time by logging into Chatter and going to your profile settings. If you want a more comprehensive export, you can contact us to request a data export. We will provide you with a copy of your data electronically, subject to verification of your identity. Note that repeated or excessive requests may be subject to lawful limitations (we may refuse manifestly unfounded or excessive requests as allowed by law).
Correction (Rectification): You have the right to request that we correct or update any inaccurate or incomplete personal information we hold about you. How to Correct: Most of the basic information (name, email, profile info) can be corrected by you directly through your account settings (just edit your profile, update your email, etc.). If you have difficulty updating certain information or if it’s something you can’t change (like an old email that’s now tied to a blocked account), you can contact us with the request, and we will rectify the data if appropriate. We may ask for documentation to verify the correct information in some cases.
Deletion (Right to Erasure): You have the right to request deletion of your personal information. This right is sometimes called the “right to be forgotten.” How to Delete: The easiest way to delete your data is to delete your account via Chatter’s settings. In your account settings, you will find an option to delete or deactivate your account. Initiating that process will deactivate your account and eventually result in deletion of your data as described in the Data Retention section. If you prefer, you can also contact us directly to request deletion of specific data or your entire account. Please note: (a) We may need to retain certain information for legal or legitimate purposes (as detailed in Data Retention) – if so, we will inform you. (b) Once your account is deleted, you will lose access to Chatter and this action is generally irreversible after the grace period. (c) Content you posted that has been re-shared or is stored by others (e.g., someone saved a clip of your public audio) is not something we can fully remove from the world, though it will be removed from our platforms.
Portability: For jurisdictions that provide this right (e.g., GDPR, LGPD), you can request a portable copy of certain information that you have provided to us in a structured, commonly used, machine-readable format. For example, you might request a JSON or CSV file of your posts, profile information, and other basic account data. This can help you in transferring to another service. We provide such exports to the extent required by law. Currently, you can contact us to request data portability, and we will guide you through the process (we may build automated export tools in the future to simplify this).
Withdraw Consent: In cases where we rely on consent to process your personal information, you have the right to withdraw that consent at any time. For instance, if you consented to us processing your photos for AI avatars, you can withdraw consent by deleting the avatars and contacting support to ensure we delete any remaining related data. If you consented to receive marketing emails, you can withdraw by unsubscribing. Withdrawing consent will not affect the lawfulness of any processing we already conducted based on your consent, but it will stop that specific future processing. Some features might not work properly if you withdraw consent (for example, Luna’s personalization might not function without access to your engagement data, but you can ask to opt-out of certain personalization if you wish).
Objection to Processing: You have the right to object to certain processing of your data, especially if we are processing it on the basis of a legitimate interest. For example, you can object to the use of your data for direct marketing or for our personalization algorithms. If you object, we will reconsider our processing in light of your circumstances. In many cases, we will comply with your objection and stop the processing (e.g., if you object to marketing, we will cease marketing communications to you). If we have compelling legitimate grounds to continue (for example, continued processing is necessary to prevent fraud or comply with law), we will inform you of those grounds. To object, you can contact us specifying which processing activity you object to. Additionally, in the app settings, we may provide specific toggles (like a “Personalized Content” toggle) allowing you to reduce or turn off certain types of data processing such as personalized recommendations. Adjusting those settings will be a form of objection/opt-out that we will honor.
Restriction of Processing: In certain situations, you have the right to request that we limit or “freeze” the processing of your data. This could apply if you contest the accuracy of the data (while we verify it), or if you believe our processing is unlawful but you prefer a restriction over deletion, or if we no longer need the data but you need us to keep it for a legal claim. When processing is restricted, we will store your data but not actively use it. If you believe you have a basis for restriction, please reach out to us. We will evaluate and, if the criteria are met, implement the restriction. We will also let you know before lifting any such restriction.
California Privacy Rights: If you are a California resident, the CCPA/CPRA provides you with specific rights, many of which overlap with those above. You have the right to know what categories of personal information we collect, the categories of sources, the business purpose for collection, the categories of third parties with whom we share it, and specific pieces of information we have about you. This Privacy Policy is intended to provide those details. You also have the right to request that we delete your personal info (subject to exceptions) and the right to correct inaccurate personal info. Additionally, you have the right to opt-out of the “sale” or “sharing” of your personal information. As stated, we do not sell personal data, and we only share it for purposes that fall under service provisioning. If we ever engage in practices that fall under “sharing for cross-context behavioral advertising,” we will provide a “Do Not Sell or Share My Personal Information” link or setting for you to opt out, in compliance with California law. You have the right to non-discrimination for exercising your privacy rights – meaning we will not deny you our service or provide a different level of service just because you exercised any of these rights. California also provides that you may use an authorized agent to make requests on your behalf (we will take steps to verify the agent’s authority and your identity for security). To exercise your California rights, you can contact us as described below. We will confirm receipt of your request within 10 days and respond within 45 days as required (or notify you if an extension is needed).
Brazil (LGPD) Rights: If you are in Brazil, you have rights under the LGPD largely similar to the above: confirmation of processing, access, correction, anonymization or deletion of unnecessary data, data portability, information about entities with whom we have shared your data, the possibility to withdraw consent, and to lodge a complaint with ANPD (the Brazilian Data Protection Authority). Our process for Brazilian users is also to contact us to exercise these rights. We may ask for information to verify your identity and ensure security when fulfilling such requests.
Other Regions: Likewise, if you are in jurisdictions like Canada, Australia, or elsewhere that provide privacy rights, we will accommodate your requests to the extent required by law. Even if not legally required, we will endeavor to grant you similar controls over your data because we believe it’s the right thing to do.

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How to Exercise Your Rights: To make any request regarding your personal data, you can contact us via the methods in the Contact Us section of this Policy. Please clearly describe your request – for example, “I am requesting a copy of my data” or “Please delete my account and all data associated with it.” For your security, we will need to verify your identity before fulfilling certain requests. Typically, this might involve confirming ownership of the account (logging in or providing identifying information that matches our records). If an authorized agent is making the request on your behalf (California), we will require proof of their authority and verification of you (or your power of attorney, etc., depending on the request type). We aim to respond to all valid requests within the timeframe required by law (e.g., within 1 month for EU, and within 45 days for CCPA, with possible extensions). We will inform you if we need more time and why. If we decline your request (either fully or partially), we will explain the reason, unless prohibited by law. Some common reasons might be: the request is unfounded or excessive, it infringes on the rights of others (e.g., deleting data we are required to keep for safety), or we cannot verify your identity.

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Privacy Controls: Apart from formal requests, Chatter provides you with various controls and settings to manage your information directly:

You can edit or delete content you have posted.
You can adjust your profile visibility (we plan to introduce more fine-grained privacy controls for profiles/communities in the future).
Notification preferences can be set in your account (e.g., opting out of certain notifications).
If we introduce features like contact syncing or personalized ads, there will be toggles to opt in/out.
For AI personalization, if you prefer a chronological feed or less personalization, you may toggle such a setting if available, or ask support if not directly available.

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We encourage you to explore the settings in the app to take advantage of these options. And if you need any assistance in finding or using a privacy control, just let us know.

Complaints: If you have a privacy-related concern or complaint, we would like to resolve it with you. Please contact us at the contact details below, and we will do our best to address your concerns. However, if you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority. For example, users in the EU can complain to the data protection authority in their country of residence, or to Chatter’s lead supervisory authority (if one is designated; currently, as a U.S.-based entity without an EU office, we may not have a single EU lead authority). Users in the UK can complain to the ICO, in Brazil to the ANPD, in California to the state Attorney General, etc. We will cooperate with regulators to resolve any issues. This right is without prejudice to any other administrative or judicial remedy you might have. We do kindly ask that you give us a chance to deal with your complaint first before approaching regulators, as we are committed to your privacy and may be able to answer your questions directly.

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Children’s Privacy

Chatter is not intended for children under 12 years of age. We do not knowingly collect personal information from anyone under 12. If you are under 12, please do not attempt to register for or use Chatter or send any personal information about yourself to us. If we learn that we have inadvertently collected personal data from a child under 12, we will take steps to delete that information as soon as possible.

For teens above 12: As noted, you must meet the minimum age of 12 to use Chatter, but if you are under 18 (or under the age of majority in your jurisdiction), you should use Chatter with the permission of a parent or guardian. Certain features may be restricted based on age. We encourage parents/guardians to educate their children about safe internet practices and to monitor their children’s online activities.

If you are a parent or guardian and believe that a child under 12 (or under an applicable minimum age) has provided us with personal information, please contact us immediately so that we can take appropriate action. We will promptly delete the data and terminate the child’s account.

California Minors: If you are a registered user in California under age 18, you may request removal of content or information you have publicly posted on our Services. To do so, please contact us with specifics of what content you want removed. We will make reasonable good faith efforts to remove or anonymize such content from public view, or explain if we are unable (for example, if the content has been re-posted by others). Please note, removal does not ensure complete erasure (e.g., it might remain in backups or if someone else reposted it, that’s outside our control), but we will handle the request per California law.

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Data Security

We take security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. Chatter uses a combination of administrative, technical, and physical safeguards designed to protect data:

Encryption: We employ encryption to protect data in transit and at rest. For example, our website is served over HTTPS (TLS encryption) to secure data transmission. Sensitive data (like passwords and payment information) is encrypted. We hash and salt passwords, so they are not stored in plaintext.
Access Controls: We limit access to personal data to authorized employees, contractors, and service providers who need it to operate or improve our Services. They are subject to strict confidentiality obligations. Internal access to systems requires authentication and follows the principle of least privilege (only the minimum necessary access).
Network & System Security: Our servers are protected by firewalls and monitoring systems to detect and prevent intrusions. We regularly update our software and infrastructure to address security vulnerabilities. We use secure cloud infrastructure with built-in safeguards. We also employ anti-virus and anti-malware protections as needed.
Testing and Assessments: We periodically review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access. We may conduct security audits and penetration testing through third-party specialists.
Employee Training: Our team members are trained on data privacy and security best practices. We have internal policies in place to handle data securely and to respond properly in the event of an incident.
Incident Response: In the event of a data breach or security incident, we have procedures to promptly address and mitigate the issue. Where required by law, we will notify you and/or the appropriate authorities of certain breaches. For example, for EU users, we would notify the relevant Data Protection Authority and possibly users of a breach affecting personal data within the timeline mandated by GDPR.

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Despite all these efforts, it’s important to understand that no security measures are 100% perfect. We cannot guarantee absolute security of data. You also play a role in keeping your information secure: please use a strong, unique password for Chatter and do not share it. Be careful about giving out sensitive info in places like your profile or public chats. If you suspect any unauthorized access to your account or any security vulnerabilities, notify us immediately.

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Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. If we make changes, we will post the updated Privacy Policy on our website (and in the app) and update the “Last Updated” date at the top. The most current version of the Policy will govern our use of your information

If we make any material changes (meaning changes that substantially affect your rights or how we use personal data), we will provide a more prominent notice. For example, we might notify you via email or by placing a notice within the app, and we may seek your consent to those changes if required by law. We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

Your continued use of Chatter after any changes to this Privacy Policy signifies your acceptance of the updated terms, to the extent permitted by law. If you do not agree to any updated terms, you should stop using the Services and, if applicable, delete your account.

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Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to contact us:

Chatter Social Inc.
Attn: Privacy Team (Data Protection Officer)
10411 Motor City Dr #350
Bethesda, MD 20817
United States

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Email: [email protected]
In-App Support: You may also contact us through the help/support section in the Chatter app.

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We will do our best to respond promptly to your inquiry. For security and privacy, we may need to verify your identity before disclosing or discussing personal data.

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If you prefer to contact our EU/UK representative or have questions specific to GDPR compliance, please email us and we will direct you to our designated representative (if applicable) or address your concern directly.

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Thank you for trusting Chatter with your personal information. We are continuously working to protect your privacy and create a safe, enjoyable community for everyone.