Privacy Policy

1. Introduction

Welcome to Comexp ("we," "our," or "us"). We are committed to protecting your privacy and being transparent about how we collect, use, and protect your information. This Privacy Policy explains our data practices for both our website and mobile application, which operate through our shared API infrastructure.

2. Information We Collect

2.1 Authentication Information

We use third-party authentication services (Telegram and Google) to verify your identity. Through these services, we may receive:

• User ID from the authentication platform
• Display name or username
• Profile picture (when provided by the platform)
• Email address (if included in the authentication scope)

2.2 Email Address (Optional)

You may choose to provide an email address additionally through your account dashboard for communication purposes.

2.3 Video Processing Data

When you use our video processing features:

• Temporary Processing: We temporarily receive and process chunks of your videos on our servers
• Immediate Deletion: Original video chunks are immediately deleted after sending you a progress update through our progress bar or through our websocket at wss://api-dev.comexp.net/processing-websocket
• Indexed Data: For personal archive functionality, we may retain indexed, non-reconstructible mathematical representations of your videos that cannot be used to recreate or view the original content
• Otherwise: During general usage outside of the personal archive functionality, we do not retain any of your video or index data

2.4 Usage Information

During usage we collect basic usage information to provide our functionality, such as:

• Usage patterns
• Error logs and diagnostic information

3. How We Use Your Information

3.1 Service Provision

• Authentication: To verify your identity and maintain your account
• Video Processing: To provide our core video analysis and processing services
• Personal Archives: To maintain and search your personal video archives (only when you choose this feature)
• Summary Generation: To perform automated statistical analysis (not artificial intelligence) to identify dynamic video segments

3.2 Communication

• Service Notifications: To send essential account information, including subscription status, payment notifications, security alerts, and service updates
• Optional Updates: To send product updates, feature announcements, and tips (only with your explicit consent and if applies)

3.3 Service Improvement

• To analyze usage patterns and improve our services
• To troubleshoot technical issues
• To ensure service security and stability

4. Our Video Processing Features

4.1 Archive Search

When you search our existing video archive:

• No personal video data is stored
• Searches are processed against our existing database only
• Your anonymised search queries (i.e their cost in "Tokens") may be logged for business purposes

4.2 Personal Archive Creation

When you choose to create a personal archive:

• We store indexed, mathematical representations of your videos
• These indices cannot be used to reconstruct or view your original videos
• This data is retained to enable search functionality within your personal archive
• You can delete your personal archive data at any time from your dashboard

4.3 Video Summary Feature

Our summary feature:

• Uses automated statistical analysis (not artificial intelligence) on video indices
• Identifies dynamic segments in your videos
• Returns timing information (keyframe numbers) to your device
• Your original video remains stored entirely within your browser during playback

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

We may share limited information with trusted service providers who assist us in operating our service, including:

• Authentication services (Telegram, Google)
• Payment processors (if applicable and currently in use. Note: NOT in use as of 24.06.2025)

These providers are bound by confidentiality agreements and may only use your information to provide services to us.

5.2 Legal Requirements

We may disclose your information if required by law, legal process, or to:

• Comply with legal obligations
• Protect our rights or property
• Investigate potential violations of our terms
• Protect the safety of our users or the public

5.3 No Sale of Personal Data

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Regular security assessments
• Access controls and authentication requirements
• Secure data processing environments
• Immediate deletion of temporary video files

7. Data Retention and Deletion

7.1 Account Information

We retain your account information as long as your account remains active or as needed to provide services.

7.2 Video Processing Data

• Original Videos: Immediately deleted after processing
• Indexed Data: Retained only for personal archive functionality and deleted when you delete your archives or account

7.3 Communication Preferences

Email preferences and communication history (if applicable) are retained according to legal requirements and your account status.

7.4 User-Controlled Deletion

You maintain full control over your data through your account dashboard and can:

• Delete your personal archive data at any time
• Remove your optional email address
• Delete your entire account and associated data
• Update your communication preferences

8. Your Rights and Choices

8.1 Access and Control

You have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Delete your personal information (subject to legal retention requirements)
• Export your data in a portable format as is per EU regulations
• Object to certain processing activities

8.2 Communication Preferences

You can control how we communicate with you:

• Essential Communications: Required for service operation (cannot be disabled while account is active)
• Marketing Communications: Completely optional and can be disabled at any time
• Unsubscribe: Available in all marketing emails with immediate effect

8.3 Authentication Data

Since we use third-party authentication, you can manage your authentication preferences directly through Telegram or Google's privacy settings.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your information during such transfers, including:

• Standard contractual clauses
• Adequacy decisions
• Other lawful transfer mechanisms

10. Legal Basis for Processing (GDPR)

If you are in the European Economic Area, our legal basis for processing your personal information includes:

• Contractual Necessity: To provide the services you have requested
• Legitimate Interests: To improve our services and ensure security
• Consent: For optional communications and features (which you can withdraw at any time)

11. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights including:

• Right to know what personal information we collect and how it's used
• Right to delete personal information (subject to exceptions)
• Right to opt-out of the sale of personal information (note: we do not sell personal information)
• Right to non-discrimination for exercising these rights

To exercise these rights, contact us using the information provided in Section 13.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will:

• Post the updated policy on our website and in our application
• Update the "Last Updated" date
• Notify you of material changes via email (if you have provided an email address) or through our service
• For significant changes, we may seek your renewed consent where required by law

13. Contact Us

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

For specific privacy requests (access, deletion, correction), please include:

• Information to verify your identity in our systems, such as your contact information, email or API key
• A description of your request

We will respond to your privacy requests within 30 days (or as required by applicable law).