ColiMe Privacy Policy

Effective Date: December 29, 2025

Issuing Entity: RUNTO VELY INC (hereinafter referred to as "we")

Company Address: 65 Trailwood, Irvine - 92620-1242, United States (US)

Contact Email: swagacollins2@gmail.com

Controller: The controller of personal information processing for this Application is RUNTO VELY INC (Company), responsible for decision-making and overall management of personal information processing. Contact Information: swagacollins2@gmail.com (please indicate "Inquiry/Application to Controller + Specific Matter" when contacting).

Data Protection Officer (DPO): The specific person responsible for supervising the personal information processing activities of this Application and safeguarding users' privacy rights and interests. Name: Arthur George Watson. Contact Information: swagacollins2@gmail.com (please indicate "Inquiry/Application to DPO + Specific Matter" when contacting).

ColiMe is a cross-border social application (hereinafter referred to as "this Application" or "the Service"). Through this platform, you can meet interesting users from around the world and enjoy convenient chat interactions and friendship experiences.

This Privacy Policy aims to inform you about how we collect, use, store, share, and protect your personal information (as defined below), as well as the privacy rights and interests you are entitled to as a user in accordance with the law and the ways to exercise them. This Policy applies to all your activities of accessing and using this Application and related services.

Please carefully read and fully understand all the contents of this Privacy Policy before using this Application and the Service. By clicking "Agree", "Accept", or actually using this Application and the Service, you acknowledge and agree to all the terms of this Policy, including our collection, use, sharing, and other processing of your personal information. If you do not agree to any content of this Policy, please immediately stop accessing or using this Application and the Service.

I. Definitions

• Personal Information: Refers to various types of information recorded in electronic or other forms that can identify a specific natural person individually or in combination with other information, or reflect the activities of a specific natural person, including but not limited to identity information, contact information, device information, and usage behavior information.

• Sensitive Personal Information: Refers to personal information that may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment once leaked, illegally provided, or abused, including but not limited to biometric information, precise location information, and financial account information.

• Device ID: Refers to a string of characters used to uniquely identify the mobile device you use, including but not limited to IMEI, MEID, Android ID, IDFA, OAID, etc., used to ensure the normal operation of the Application, identify device status, and optimize service experience.

• Advertising IDs: Refers to device-related identifiers used for advertising delivery and effect tracking, including but not limited to IDFA (iOS devices), OAID (Android devices), IDFV, etc., which can help us and advertising partners evaluate advertising effects and optimize advertising delivery strategies.

• Data Sale: Refers to the act of us transferring your personal information to a third party for economic benefits, excluding the necessary data sharing for providing services.

• Data Sharing: Refers to the act of us providing your personal information to third-party service providers, partners, and other entities for the purpose of realizing service functions and optimizing service experience, excluding data sale.

II. Information We Collect

We only collect necessary personal information for the purposes stated in this Policy and will not collect information beyond a reasonable and necessary scope. We collect information through the following three ways:

(I) Information You Voluntarily Provide

Personal information you actively provide to us during the registration and use of this Application and the Service, including but not limited to:

• Account Information: We will automatically generate a unique User ID for you, which is your identity identifier on this platform. You are obligated to keep this ID properly and shall not disclose or transfer it.

• Interaction Information: Texts, pictures, voices, videos, and other contents you send through this Application, as well as dynamics, comments, likes, and other information you post in the community.

• Inquiry and Feedback Information: Relevant information you actively provide when submitting complaints or suggestions to us, such as problem descriptions.

The personal information you actively provide (except for the User ID) can be modified at any time through the "Me - Settings" page of this Application; your public information such as nickname and avatar will be displayed to your contacts and other users on the platform, and you can independently set the public scope of the information.

(II) Information Automatically Collected When You Use the Service

When you use this Application and the Service, we will automatically collect your usage behavior information and device-related information through the application program to ensure the normal operation of the Service and optimize the service experience, including but not limited to:

• Device Information: Including Device ID (such as IMEI, MEID, Android ID, IDFA, OAID, IDFV), Advertising ID, device model, operating system version, screen resolution, network type, device storage capacity, battery status, etc.

• Location Information: If you enable the device location permission and agree to our collection, we will collect your approximate location information (obtained through IP address, base station information, etc.) to recommend nearby users or local relevant content for you; you can turn off the location permission in the device settings or application settings at any time, and we will no longer collect this information after it is turned off.

• Log Information: Including your access logs, operation logs, error logs, etc., such as access time, accessed pages, operation behaviors, error codes, etc.

Permission-Related Information: If you enable the following permissions, we will collect relevant information to realize the corresponding functions. You can turn off the permissions in the device settings or application settings at any time. After turning off the permissions, you will not be able to use the corresponding functions but will not affect other services:

① Microphone Permission: Used for you to send voice messages and transmit voice data during video calls;

② Camera Permission: Used for you to take and send pictures in chats, change personal avatars, and transmit image data during video calls;

③ Photo Album Permission: Used for you to select pictures from the local photo album to send to the chat interface or to change personal avatars.

(III) Information Obtained from Third Parties

With your consent or authorization, we may obtain relevant information about you from third parties, including but not limited to:

• Relevant information provided to us by third-party service providers, partners, and other entities, such as payment status information provided by payment service providers to confirm the completion of transactions.

The information we obtain from third parties will strictly comply with the provisions of relevant laws and regulations to ensure that the acquisition is legal and compliant, and we will obtain your explicit consent before use (unless otherwise stipulated by laws and regulations).

III. How We Use Collected Information

We will strictly use the collected personal information in accordance with the provisions of this Policy, only for the following purposes:

• Provide and Maintain Services: Used for account login verification, ensuring your normal use of various functions of this Application (such as chatting, posting dynamics, using filters, etc.), handling your feedback matters, and maintaining the stable operation of the Service.

• Optimize Service Experience: By analyzing your usage behavior data, understanding your preferences, recommending personalized content, users, and services for you; optimizing the application interface design and function layout, improving service response speed, and enhancing the overall user experience.

• Ensure Account and Information Security: Using Device ID and other information to identify abnormal login behaviors, preventing risks such as account theft and fraud; detecting and handling malicious behaviors in the Application, and protecting your personal information from unauthorized access, use, or leakage.

• Comply with Legal and Regulatory Requirements: To comply with applicable laws, regulations, rules, and regulatory requirements, cooperate with legitimate investigations by judicial authorities and administrative organs, and fulfill relevant legal obligations.

• Advertising Delivery and Effect Tracking: To achieve precise advertising delivery and evaluate advertising conversion effects, we will share the collected Advertising ID and other relevant information with cooperating advertising platforms for tracking advertising reach, clicks, and subsequent application usage, and optimizing advertising delivery strategies.

• Other Purposes with Your Consent: Using the information for other legal and compliant purposes with your explicit consent.

We will not use personal information for purposes not stated in this Policy. If it is necessary to use the information for other purposes, we will obtain your explicit consent again.

IV. Data Sharing and Sale Instructions

We attach great importance to the security of your personal information, strictly control data sharing and sale behaviors, clearly inform you of the relevant situations of data sharing and sale, and protect your right to know and right to choose.

(I) Data Sharing

1. Scope and Purpose of Sharing

We will only share your personal information with the following third parties within the necessary scope to realize service functions and ensure service quality, and the shared information will only be used for the agreed purposes:

• Third-Party Service Providers: To realize specific functions of this Application, we may share information with third-party service providers that provide us with technical support, payment services, data analysis, customer service, etc. For example, sharing your order information (excluding sensitive payment passwords) with payment service providers to complete payments; sharing anonymized usage behavior data (from which personally identifiable information has been removed) with data analysis service providers to optimize services.

• Advertising Cooperation Platforms: To achieve advertising delivery, effect tracking, and optimize promotion efficiency, we will cooperate with third-party advertising platforms (such as Appsflyer, Facebook, etc.) and share your Advertising ID and relevant usage behavior information (such as advertising clicks, subsequent in-app operations, etc.) with them for advertising effect statistics, conversion tracking, and optimization of advertising delivery strategies; such sharing is only for the above agreed purposes, and we will require cooperating platforms to take sufficient security protection measures and prohibit them from using the shared information for purposes other than the agreed ones.

• Partners: Other enterprises or institutions that cooperate with us, sharing information for the purposes of joint promotion, cooperative services, etc. For example, sharing your registration information with offline event organizers to ensure your smooth participation in the event.

• Other Users: The public dynamics, comments, and other information you post in this Application will be displayed to other users; the chat content between you and other users will only be transmitted between you and the recipient to ensure smooth communication.

• Entities Required by Laws and Regulations: To comply with applicable laws, regulations, rules, and regulatory requirements, or in response to legitimate requests from judicial authorities and administrative organs, share necessary personal information with relevant entities.

2. Principles and Safeguard Measures for Sharing

When sharing personal information with third parties, we will strictly abide by the following principles:

• Legality: The sharing behavior complies with the provisions of laws and regulations and obtains your explicit consent (unless otherwise stipulated by laws and regulations).

• Necessity: Only share the minimum scope of information necessary to achieve the purpose, not exceeding a reasonable and necessary scope.

• Security: Sign data processing agreements with third parties, clarify the rights and obligations of both parties, require third parties to take sufficient security protection measures to protect your personal information, and prohibit third parties from using the shared information for purposes other than the agreed ones.

3. Right to Know About Data Sharing and Inquiry Method

You have the right to know whether your personal information has been shared, the name of the third-party entity with which it has been shared, the type of shared information, and the purpose of sharing.

If you need to inquire about relevant information, you can submit an application through the method stated in the "Contact Us" chapter of this Policy, and we will complete the verification and feedback the result to you within 15 working days (unless otherwise stipulated by laws and regulations).

(II) Data Sale

1. Sale Policy Statement

Except as otherwise stipulated by laws and regulations, wewill not actively sell your personal information.

If it is necessary to sell your personal information due to special circumstances such as enterprise merger, acquisition, or asset transfer, we will inform you of the purpose, scope, recipient, and other information of the sale through pop-ups, official announcements, and other methods in this Application 7 working days in advance, and obtain your explicit consent; at the same time, we will sign a strict data processing agreement with the recipient to ensure the security of your personal information.

2. Right to Know About Data Sale and Inquiry Method

You have the right to know whether your personal information has been sold, the purpose, scope, recipient of the sale, and the economic benefits obtained, etc.

3. Right to Opt Out of Data Sale and Exercise Method

You have the right to opt out of data sale. If you do not agree to our sale of your personal information, you can exercise the right to opt out through the following methods:

• Directly click "Reject" or "Disagree" on the pop-ups, announcements, and other pages where we inform you of the sale information;

• Submit an opt-out application through the method stated in the "Contact Us" chapter of this Policy, indicating your account, contact information, and application matters.

After you exercise the right to opt out, we will immediately stop the sale of your personal information (except for those that have been sold and cannot be withdrawn, but we will require the recipient to stop using and delete the relevant information).

(III) Right to Opt Out of Targeted Advertising and Exercise Method

We may push targeted advertisements to you based on your usage behavior data, and you have the right to opt out of targeted advertising.

Exercise Method: You have the right to opt out of targeted advertising pushes, and the only way to exercise this right is to submit an application to us through the email stated in the "Contact Us" chapter of this Policy, indicating your account and the application matter of "Opt Out of Targeted Advertising". We will process it immediately after receiving the application and stop pushing personalized advertisements to you, but may still push non-targeted general advertisements to you.

V. Specific Rights of Users in Different Countries/Regions

We respect the privacy protection laws and regulations of different countries and regions around the world. For users in different jurisdictions, in addition to the general rights and interests stated in this Policy, you also enjoy the following specific rights and interests (in accordance with the provisions of the laws and regulations of the corresponding regions):

(I) Users in the European Union (Applicable to the General Data Protection Regulation (GDPR))

• Right to Know: You have the right to know all the circumstances of the collection, use, sharing, and sale of your personal information by us, including the source of the information, the purpose of processing, the method of processing, etc.

• Right of Access: You have the right to require us to provide a copy of your personal information, including the storage location of the information, sharing/sale records, etc.

• Right to Rectification: If you believe that the personal information we hold about you is incorrect or incomplete, you have the right to require us to correct or supplement it in a timely manner.

• Right to Erasure (Right to Be Forgotten): In the following circumstances, you have the right to require us to delete your personal information: ① We no longer need the information for the purpose of processing; ② You withdraw your consent; ③ Our processing behavior violates laws and regulations; ④ You are a minor.

• Right to Restriction of Processing: In circumstances where there is a dispute over the accuracy of the information, the processing behavior is illegal but you do not require deletion, we no longer need the information but you need it for rights protection, etc., you have the right to require us to restrict the processing of your personal information.

• Right to Data Portability: You have the right to require us to provide your personal information in a structured, commonly used, and machine-readable format to you, or directly transmit it to another data controller designated by you (subject to technical feasibility requirements).

• Right to Withdraw Consent: You have the right to withdraw your consent to the collection, use, sharing, and sale of your personal information by us at any time. The withdrawal of consent will not affect the legality of the processing behaviors based on your consent before the withdrawal.

• Right to Lodge a Complaint: If you believe that our personal information processing behavior violates the provisions of the GDPR, you have the right to lodge a complaint with the relevant data protection supervisory authority of the European Union.

Exercise Method

You can submit an application for exercising the above rights through the method stated in the "Contact Us" chapter of this Policy, and you need to provide your account, identity certification materials (such as a copy of your passport), and specific application matters. We will complete the processing and feedback the result to you within the time limit stipulated by the GDPR (generally no more than 1 month, which can be extended to 3 months in complex cases).

(II) Users in the United States (Applicable to the California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), etc.)

1. California Users (CCPA/CPRA)

• Right to Know: You have the right to require us to inform you of the categories, sources, purposes of use of your personal information collected by us in the past 12 months, as well as the names of third-party entities with which it has been shared/sold and the categories of information.

• Right of Access: You have the right to require us to provide a copy of your personal information collected in the past 12 months.

• Right to Deletion: You have the right to require us to delete your collected personal information (except for circumstances stipulated by laws and regulations, such as information that needs to be retained to fulfill legal obligations, ensure service security, etc.).

• Right to Opt Out of Data Sale: You have the right to opt out of our sale of your personal information, and we shall not discriminate against you for exercising this right (such as increasing service prices, reducing service quality, etc.).

• Right to Non-Discrimination: Your exercise of any right under this Policy will not result in a reduction in the quality of services you receive or the imposition of unreasonable fees.

2. Virginia Users (VCDPA)

• Right to Know: You have the right to know the circumstances of the collection, use, and sharing of your personal information by us, including the categories of information and the purposes of processing.

• Right of Access: You have the right to require us to confirm whether your personal information is being processed and to obtain a copy of the information.

• Right to Rectification: You have the right to require us to correct inaccurate or incomplete personal information.

• Right to Deletion: You have the right to require us to delete your personal information (except for exceptional circumstances).

• Right to Data Portability: You have the right to require us to provide your personal information in a structured, commonly used, and machine-readable format to you or a designated third party.

• Right to Opt Out: You have the right to opt out of the processing of your personal information by us for the purposes of targeted advertising and user profiling.

Exercise Method

You can submit an application for exercising rights through the method stated in the "Contact Us" chapter of this Policy, and you need to provide your account, contact information, and specific application matters (for California users applying to opt out of data sale, you can directly operate through the "Me - Settings - Privacy Settings - California User Rights" page of this Application). We will complete the processing and feedback the result to you within the time limit stipulated by the laws of the corresponding state.

(III) Users in India (Applicable to the Digital Personal Data Protection Act, 2023 (DPDP Act))

• Right to Know: You have the right to know the purpose of collecting your personal information by us, the categories of information, and the storage period of the information.

• Right of Access: You have the right to require us to provide a copy of your personal information.

• Right to Rectification: If your personal information is incorrect or incomplete, you have the right to require us to correct or supplement it.

• Right to Deletion: When the purpose of our processing has been achieved, the storage period has expired, you withdraw your consent, and other circumstances, you have the right to require us to delete your personal information.

• Right to Withdraw Consent: You have the right to withdraw your consent to the processing of personal information at any time. The withdrawal of consent will not affect the legality of the processing behaviors before the withdrawal.

• Right to Lodge a Complaint: If you believe that our personal information processing behavior violates the provisions of the DPDP Act, you have the right to lodge a complaint with the Indian data protection authority.

Exercise Method

You can submit an application for exercising rights through the method stated in the "Contact Us" chapter of this Policy, and you need to provide your account, identity certification materials, and specific application matters. We will complete the processing and feedback the result to you within the time limit stipulated by the DPDP Act.

(IV) Users in Other Countries/Regions

For users in other countries/regions, we will strictly comply with the applicable local privacy protection laws and regulations and protect all the privacy rights and interests you are entitled to in accordance with the law. If you need to know the specific content of the rights and interests and the exercise methods, you can consult us through the method in the "Contact Us" chapter.

VI. Storage and Protection of Information

(I) Storage Period and Location

1. Storage Period: We will store your personal information for the shortest period necessary to achieve the processing purposes stated in this Policy. After the expiration of the storage period, we will process your personal information by means of anonymization or secure deletion (except as otherwise stipulated by laws and regulations, such as information that needs to be retained to fulfill legal obligations, resolve disputes, etc.).

2. Storage Location: Your personal information will be stored on our servers and the servers of third-party service providers, which are distributed in the United States, the European Union, India, and other countries/regions where we provide services. By using this Application and the Service, you agree to our transmission of your personal information to servers outside your country/region for storage and processing.

(II) Security Protection Measures

We attach great importance to the security of your personal information and take industry-standard security protection measures to prevent personal information from unauthorized access, use, modification, leakage, or loss, including but not limited to:

• Data Encryption: Encrypting sensitive personal information (such as mobile phone numbers, login passwords) using encryption algorithms such as AES-256 for encrypted storage and transmission to ensure the security of information during transmission and storage; for Advertising ID and other information shared with advertising platforms, security measures such as encrypted transmission will be adopted.

• Technical Protection: Deploying technical facilities such as firewalls, Intrusion Detection Systems (IDS), and Intrusion Prevention Systems (IPS) to prevent risks such as network attacks and malicious intrusions.

• Access Control: Establishing a strict access control mechanism, conducting identity authentication and permission management for personnel accessing personal information, and only authorized personnel can access relevant information within the authorized scope; regularly auditing access logs to ensure that access behaviors are traceable.

• Personnel Management: Conducting privacy protection training for internal employees, clarifying employees' information security obligations; signing confidentiality agreements with employees, and holding employees who violate confidentiality obligations legally responsible.

• Emergency Response: Formulating an emergency response plan for personal information security incidents. In the event of security incidents such as information leakage or loss, the emergency response plan will be activated immediately, remedial measures will be taken, and you and the relevant supervisory authorities will be reported in a timely manner in accordance with the requirements of laws and regulations.

Please note that although we have taken the above security measures, no system is absolutely secure. We cannot guarantee that your personal information will not be illegally accessed, used, or leaked at all, and you shall bear the corresponding risks arising from the use of this Application and the Service (such as information security issues caused by the leakage of your account password due to your own reasons).

VII. Your Control Rights Over Personal Information

In addition to the rights and interests stated in Chapters IV and V of this Policy, you also enjoy the following control rights over your personal information, and we will provide you with convenient exercise channels:

• Right to Account Cancellation: You have the right to cancel your ColiMe account. After canceling the account, we will stop providing services for you and delete your personal information after the expiration of the storage period (except as otherwise stipulated by laws and regulations).

• Right to Information Modification: You can modify your personal information such as nickname, avatar, and contact information at any time through the "Me - Settings" page of this Application (the User ID cannot be modified).

• Right to Permission Management: You can independently enable or disable permissions such as location, camera, microphone, and photo album in the device settings or application settings to control our collection of relevant information; after disabling the permissions, the corresponding functions (such as video calls, sending voices/pictures, etc.) will not be available, but it will not affect the normal use of other services.

Exercise Method

1. Account Cancellation: Submit a cancellation application through the "Me - Settings - Account Security - Cancel Account" page of this Application, and complete the identity verification as prompted to cancel; before cancellation, please ensure that you have settled all unfinished transactions, and the account-related information cannot be recovered after cancellation.

2. Other Rights: Can be directly operated through the application settings page or by submitting an application through the method in the "Contact Us" chapter.

VIII. Protection of Minors

This Application and the Service are not intended for minors under the age of 18 (hereinafter referred to as "minors"). We will not intentionally collect personal information from minors.

If you are a minor, please do not register or use this Application and the Service; if a minor registers and uses this Application and the Service without the consent of a guardian, the guardian may submit an objection application to us through the method in the "Contact Us" chapter, requesting the deletion of the minor's personal information. After verifying the situation, we will immediately stop providing services for the minor and delete the relevant personal information.

IX. Revision of the Privacy Policy

We may revise this Privacy Policy from time to time in accordance with the update of laws and regulations, the adjustment of service functions, the needs of business development, and other circumstances.

When significant changes occur to this Privacy Policy (such as significant changes in the purpose and scope of collecting, using, and sharing personal information, significant adjustments in the way of protecting users' rights and interests, etc.), we will inform you of the changed content 7 working days in advance through pop-ups, official announcements, in-app messages, and other methods in this Application, and obtain your explicit consent; for non-significant changes, we will update the revised Privacy Policy in a prominent position of this Application and update the effective date, which you can check at any time.

The revised Privacy Policy shall take effect from the effective date. If you continue to use this Application and the Service, it means that you have acknowledged and agreed to the revised Privacy Policy.

X. Contact Us

If you have any questions, opinions, or suggestions about this Privacy Policy, or need to exercise any right under this Policy, you can contact us through the following sole method:

• Contact Email: swagacollins2@gmail.com

• Company Address: 65 Trailwood, Irvine - 92620-1242, United States (US)

We will complete the verification and feedback the result to you within 15 working days after receiving your contact request (unless otherwise stipulated by laws and regulations). If you are not satisfied with our feedback result, you can lodge a complaint with the relevant data protection supervisory authority of your country/region.

Thank you for your trust and support to ColiMe! We will continue to improve our privacy protection work and safeguard your legitimate rights and interests.

RUNTO VELY INC

December 25, 2025