Comcarte Privacy Policy

Introduction

Comcarte (the “App”) is operated by SC Games, owned by Sean Grace, Ireland (“SC Games”, “we”, “our”, or “us”).

By creating an account, confirming that you meet the minimum age requirement, or using Comcarte, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

Account information

When you create an account, we collect:

• Email address
• Username
• Display name
• Password
• Date of birth (requested during account creation solely to verify that you meet the minimum age requirement)

Passwords are managed by Firebase Authentication. SC Games does not receive or store your password in plain text.

Before creating an account, Comcarte asks you to provide your date of birth solely to verify that you meet the minimum age requirement. Unless required by law or needed to support the age-verification process, we do not retain your full date of birth after verification.

Profile information

You may choose to provide:

• Profile picture
• Profile banner
• Biography or other profile information
• Profile privacy preference, such as Public or Private

User content

When using Comcarte, you may create or upload:

• Memory photos
• Trip information
• Captions and descriptions
• Chat messages
• Other content you choose to share through the App

You remain responsible for content that you upload or share.

Location information

With your permission, Comcarte may access your device’s location while you are using the App. Location sharing is optional and may be enabled or disabled through the App’s settings.

Comcarte does not currently collect location while the App is not in use. If background location features are introduced in the future, this Privacy Policy and the relevant permission notices will be updated.

Device and technical information

We may process limited technical information, including:

• Device type
• Operating system version
• App version
• Push notification token
• Technical information required to operate and secure the App

2. How We Use Your Information

We use information collected through Comcarte to:

• Create, authenticate, and manage your account
• Display and operate user profiles
• Allow users and friends to interact
• Display memories and trips
• Provide chat and messaging features
• Provide location sharing when you enable it
• Deliver push notifications you have permitted
• Maintain, troubleshoot, and secure the App
• Detect fraud, abuse, or misuse
• Comply with applicable legal obligations
• Verify that users meet the minimum age required to create an account

We do not sell your personal information.

3. Legal Basis for Processing

Where the General Data Protection Regulation (GDPR) applies, we process personal information on one or more of the following legal bases:

• Performance of a contract to provide the Comcarte service.
• Compliance with applicable legal obligations where required, and otherwise our legitimate interest in operating a service intended only for users aged 16 and over.
• Legitimate interests, such as protecting the security and integrity of Comcarte and preventing fraud or abuse.
• Consent, where required by applicable law.

4. Profile Privacy

Comcarte allows you to select a profile privacy setting.

Certain basic information may still need to be processed to operate your account, prevent abuse, and respond to interactions you initiate.

5. Location Sharing

Location sharing is optional.

If you enable it:

• Your location may be visible to friends or other users permitted by the App’s sharing features.
• Location data is processed so that your position can be displayed on the map.

You may disable location sharing at any time. Once disabled, Comcarte will stop actively updating your shared location, although technical delays or cached information may briefly remain visible.

6. Chats

Comcarte provides private messaging features. Chat messages are currently stored through Firebase Realtime Database.

Chats are not currently end-to-end encrypted. This means they are not protected by a system where only the sender and intended recipient hold the keys needed to read them.

We may introduce additional message encryption in the future. This policy will be updated when the handling of chat data changes.

7. Photos and Uploaded Content

Photos and other uploaded files may be stored using Google Firebase Storage. This may include:

• Profile pictures
• Profile banners
• Memory photos

Visibility depends on the applicable profile, friendship, trip, and sharing settings within Comcarte. Do not upload content that you do not have the right or permission to share.

8. Community Standards

To help keep Comcarte safe, we may investigate reports or suspected misuse of content or behaviour that may violate our Terms of Service or applicable law. This may include reviewing user-generated content where reasonably necessary to investigate a report or protect the safety and security of our users.

9. Push Notifications

With your permission, Comcarte may send push notifications relating to:

• New messages
• Friend requests
• Trip activity
• Account, security, and service-related updates

You may disable notifications through Comcarte’s settings or through your device’s operating-system settings.

10. Third-Party Services

Comcarte relies on third-party service providers to operate. These may include:

• Firebase Authentication
• Firebase Realtime Database
• Firebase Storage
• Expo Push Notifications
• Expo Maps
• Google Maps on supported Android devices
• Apple Maps on supported Apple devices
• Expo Application Services (where applicable)

These providers may process information as required to deliver their services and may operate under their own privacy policies and terms.

Comcarte does not currently use advertising services or behavioural advertising. If advertising or analytics services are introduced, this policy will be updated before or when those services begin processing user information.

11. Data Security

We take reasonable technical and organisational measures to protect information from unauthorised access, loss, misuse, alteration, or disclosure.

Access to personal information, including information used for age verification, is limited to authorised systems and personnel where required for operating and securing the App.

No electronic transmission or storage system is completely secure. We therefore cannot guarantee absolute security.

12. International Users and Data Transfers

Comcarte is intended to be available internationally. Your information may be processed or stored in countries other than the country in which you live, including through our service providers.

Where required, we will rely on appropriate legal grounds and safeguards for international transfers of personal information.

13. Your Rights and Choices

Depending on where you live, you may have rights relating to your personal information, including the right to:

• Request access to information held about you
• Correct inaccurate or incomplete information
• Request deletion of your account and eligible information
• Object to or restrict certain processing
• Withdraw permissions such as location access
• Request information about how your date of birth is processed for age verification
• Request a portable copy of certain information
• Complain to an applicable data-protection authority

You may contact us using the details below to exercise an applicable right. We may need to verify your identity before completing a request.

14. Account Deletion and Retention

Before public release, Comcarte is intended to provide a way for users to request or initiate account deletion.

Deleting an account will remove personal information associated with that account where technically and legally possible. Some information may remain where necessary, including:

• Messages already delivered to another user, which may remain in that user’s conversation history
• Shared trip information or content involving other users
• Records required for security, fraud prevention, dispute resolution, or compliance with law
• Temporary backup copies retained for a limited period

The precise deletion process and retention periods may be updated as the account-deletion feature is finalised. This policy should be reviewed again before release to ensure that it matches the App’s actual deletion behaviour.

If your account is deleted, any date of birth information retained solely for age verification will also be deleted unless we are legally required to retain it for a longer period.

Uploaded photos and other files associated with your account will also be deleted from Firebase Storage where technically and legally possible.

15. Children's Privacy

Comcarte is intended only for people who are at least 16 years old.

Before creating an account, users are asked to provide their date of birth so we can verify that they meet this minimum age requirement.

If a user does not meet the minimum age requirement, an account will not be created.

If we discover or reasonably believe that an account has been created by someone under the minimum permitted age, we may suspend or permanently remove that account and any associated personal information, subject to applicable law.

16. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to Comcarte, our data practices, third-party services, or applicable law.

When changes are made, the “Last updated” date at the top of this page will be revised. Where legally required, we will provide additional notice or request consent.

17. Contact Us

For questions, concerns, or requests relating to this Privacy Policy or your personal information, contact: