Privacy Policy – Comatch

1. Scope and Applicability

This Policy applies to users in:

• Mainland China (Shanghai, Beijing, Shenzhen)
• Hong Kong (SAR)
• Other international jurisdictions (as we expand globally)

We ensure data handling compliance with:

• PIPL (China)
• GDPR (EU)
• CCPA (California, USA)

2. What Information We Collect

a. Information You Provide

• Profile Data: Name, email, phone number, city, LinkedIn/GitHub/portfolio links, industry interests, and skillsets
• Startup Preferences: Co-founder preferences, startup stage, industry, goals
• User-generated content: Messages, bios, pitches, founder agreements, feedback

b. Automatically Collected Information

• Device info (IP address, browser type, OS)
• Usage data (pages visited, actions taken)
• Location data (if permitted by device settings)

c. Third-party Integrations

If you sign up via LinkedIn, GitHub, WeChat, or similar, we collect basic account and public profile info (as permitted by their terms).

3. How We Use Your Information

We use your data to:

• Match users with compatible co-founders
• Enhance user experience with AI-based recommendations
• Communicate platform updates, features, or partnership offers
• Monitor platform safety and detect fraud or misuse
• Comply with legal obligations

4. Legal Basis for Processing

Depending on your location:

• In China: Based on user consent and necessity for service provision under the PIPL
• In EU: Based on GDPR-compliant lawful grounds such as consent, contract performance, and legitimate interest
• In other countries: Based on applicable data protection laws (e.g., CCPA)

5. Data Storage and Cross-Border Transfers

• User data in Mainland China is stored in local servers as required by PIPL.
• For users outside China, data may be transferred to and stored in jurisdictions with adequate data protection standards.
• We implement safeguards such as Standard Contractual Clauses and data minimization techniques.

6. How We Share Information

We do not sell your personal data at any cost.

We may share your data with:

• Matching algorithms (only anonymized or necessary data to improve user experience)
• Service providers (e.g., cloud hosting, AI infrastructure)
• Law enforcement or regulators (only when legally required)
• Partners (e.g., accelerators, incubators) with your explicit consent

7. Your Rights

Users in Mainland China:

Right to access, correct, delete, and export your personal information under PIPL

Users in EU:

Right to access, rectify, erase, restrict, object, and data portability under GDPR

Users in California, USA:

Right to know, delete, and opt out of the sale of personal information under CCPA

You can exercise your rights by emailing us at contact@comatch.ai

8. Data Retention

We retain personal data only as long as necessary to fulfill the purposes above or to comply with legal requirements. Inactive accounts may be anonymized or deleted after 24 months.

9. Security Measures

We implement industry-standard security measures:

• Encryption of sensitive data
• Access control and audit logs
• Regular penetration testing
• Data access limited to authorized personnel

10. Children's Privacy

Comatch is not intended for individuals under 18. We do not knowingly collect data from minors.

11. Changes to This Policy

We may update this policy as laws or our services evolve. We will notify users via the app or email when significant changes occur.

12. Contact Us

If you have questions or requests regarding this Privacy Policy, reach us at:

Email: contact@comatch.ai