Privacy Policy
Last updated: September 12, 2026
Introduction
Combly ("we", "us", or "our") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, store, and protect your information when you use our WhatsApp group coordination service.
Data Controller
The data controller responsible for your personal data is Combly. For data protection queries, please contact us at the details provided in the Contact section below.
What Data We Collect
We collect and process the following categories of personal data:
Account Information
Phone number, name, email address (if provided), and WhatsApp profile information
Usage Data
Information about how you use our service, including games played, polls created, events scheduled, and group interactions
Communication Data
Messages and content you share through our service for group coordination, game play, and event planning
Technical Data
IP address, browser type, device information, and cookies for service functionality and security
Payment Information
Payment card details (processed securely by our payment provider Stripe) and billing information for premium features
How We Use Your Data
We use your personal data for the following purposes:
- To provide and maintain our WhatsApp group coordination service
- To create and manage your account
- To send you service notifications, reminders, and updates via WhatsApp
- To process payments for premium features
- To improve our service, develop new features, and analyze usage patterns
- To protect against fraud, abuse, and security threats
- To comply with legal obligations and enforce our terms of service
Legal Basis for Processing (GDPR)
Under GDPR, we process your personal data based on the following legal grounds:
Performance of Contract
Processing necessary to provide our service to you
Consent
Where you have given explicit consent for specific processing activities
Legitimate Interests
For service improvement, security, and fraud prevention, where balanced against your rights
Legal Obligation
To comply with applicable laws and regulations
Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy. Account data is retained while your account is active and for up to 30 days after account deletion. Usage and communication data may be retained for up to 1 year for service improvement purposes. Payment records are retained for 7 years to comply with financial regulations.
Your Rights Under GDPR
You have the following rights regarding your personal data:
Right of Access
Request a copy of your personal data
Right to Rectification
Correct inaccurate or incomplete data
Right to Erasure
Request deletion of your personal data ("right to be forgotten")
Right to Restriction
Restrict processing of your data in certain circumstances
Right to Data Portability
Receive your data in a structured, machine-readable format
Right to Object
Object to processing based on legitimate interests
Right to Withdraw Consent
Withdraw consent at any time where processing is based on consent
Right to Complain
Lodge a complaint with your local data protection authority
To exercise any of these rights, please contact us using the details in the Contact section.
Data Sharing and Third Parties
We may share your data with:
- WhatsApp/Meta: For delivering messages and notifications through WhatsApp
- Stripe: For secure payment processing (they have their own privacy policy)
- Hosting Providers: For secure data storage and service infrastructure
- Legal Authorities: When required by law or to protect our rights
We do not sell your personal data to third parties.
International Data Transfers
Your data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission, to protect your data in accordance with GDPR requirements.
Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure servers, access controls, and regular security assessments. However, no method of transmission over the internet is 100% secure.
Cookies and Tracking
We use essential cookies to provide our service functionality. These include authentication cookies and session management. We do not use advertising or tracking cookies. You can control cookies through your browser settings, but disabling essential cookies may affect service functionality.
Manage Your Cookie Preferences
You can change your cookie preferences at any time. Click the button below to review and update your cookie settings.
Children's Privacy
Our service is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe we have collected data from a child under 16, please contact us immediately.
Changes to This Policy
We may update this privacy policy from time to time. We will notify you of significant changes via WhatsApp or email. The "Last updated" date at the top indicates when this policy was last revised.
Contact Us
For questions about this privacy policy or to exercise your rights, contact us at:
Email: privacy@combly.app
Data Protection Officer: dpo@combly.app