Legal document
Privacy policy
What we collect, why we collect it, who processes it, where it is held, how long we keep it, and what you can do about it. It was written from the running system (the app's code, the database schema and the production infrastructure) rather than from a template.
1Who we are#
1.1The controller#
CHiiRO is a community platform for founders and investors. You can build a professional profile, join communities, post and answer questions, apply to jobs, register for events and message other members.
CHiiRO is operated by RooTree Analytic Inc., a corporation incorporated in Canada ("RooTree", "we"). RooTree decides what personal information is collected and why, and is accountable for it. More about the company: rootreeinc.com.
1.2Privacy contact#
For privacy questions, rights requests and complaints, email hello@chiiro.co. If your request concerns your account, please write from the email address your CHiiRO account uses.
1.3Data protection officer#
RooTree has not appointed a data protection officer.
2What we collect, and why#
2.1Information you give us#
| What | Examples | Why | Lawful basis (where GDPR applies) |
|---|---|---|---|
| Account identity | Email address; password (stored only as a hash); or a Google or LinkedIn sign-in if you choose one | Create and secure your account; sign you in | Contract |
| One-time sign-in codes | A code emailed to you | Confirm it is you | Contract |
| Profile | First and last name, display name, phone number, date of birth, gender, city, profile photo, banner, bio | Build the profile other members see | Contract |
| Professional history | Titles, employers, dates, education, skills, interests, mentorship topics | Let members find and assess each other | Contract |
| Links | LinkedIn URL, website, portfolio | Show your work | Contract |
| Founder and investor details | Company, funding stage, investment intent, portfolio entries, company documents you upload during company verification | Match founders and investors; verify companies | Contract |
| Content you post | Discussions, questions, answers, comments, votes, bookmarks, drafts, shares | Run the community | Contract |
| Media and files | Photos, videos, documents you attach | Show them where you attached them | Contract |
| Job applications | Name, email, phone, cover letter, résumé reference | For a role a member posted on CHiiRO, send your application to that member. For a listing from an employer's job board, you apply on the employer's own page, and we receive nothing except that you tapped Apply (clause 2.4, if you allow analytics) | Contract |
| Direct messages | Messages between members, carried over the Matrix protocol on a server we run ourselves | Run messaging | Contract |
| Reports and blocks | What or whom you reported and why; who you blocked | Moderation and safety | Legitimate interest (member safety) / Contract |
Your device contacts. The invite screen can read your device's address book, but only if you allow it. This is optional, and you can refuse without losing any other feature. The contacts are read and shown on your device. We found no code in the app that sends them to our servers.
2.2Information created as you use CHiiRO#
| What | Examples | Why | Lawful basis |
|---|---|---|---|
| Account identifiers | An internal account ID and a public profile ID; a guest identifier if you browse without an account | Link your data across our services | Contract |
| Device registration | Platform, an install identifier, app version, push-notification token, which push service the device uses, and the result of a device-integrity check | Deliver notifications; keep the service secure | Contract / Legitimate interest (security) |
| Notification records | The notifications we send you (type, title and text, time sent), and whether you have read them | Show your notification history in the app (clause 2.7) | Contract |
| Delivery and open receipts | For each push notification: its message ID, the event (delivered or opened), your platform, and whether the app was open, in the background or closed. No notification content | Measure whether notifications reach people (clause 2.7) | Legitimate interest |
| Server request logs | Time, endpoint, response status, IP address, user agent, your account key when you are signed in, and request and response content | Security, abuse prevention, fixing faults (see 2.3) | Legitimate interest (security and operations) |
| Sign-in security events | Sign-in successes and failures, time, IP address, the device you used (user agent and device fingerprint), and an approximate city and country worked out from the IP address. No GPS and no coordinates | Security and fraud prevention; alerting you to a sign-in from a new device or a new country (clause 2.6) | Legal obligation / Legitimate interest |
| Location (approximate only) | The city you enter in your profile; an approximate city and country worked out from your IP address; and, only if you tap "Use my location" when looking for jobs, an approximate position from your device, rounded to about 1 km | Show relevant people, events and jobs; security | Contract / Legitimate interest |
| Search history | What you searched for, including questions to the AI search assistant | Show recent searches; improve results | Legitimate interest |
| Usage analytics and crash reports | Depends on your app version; see 2.4 | See 2.4 | See 2.4 |
| Your privacy choice (from version 1.0.16) | Your answer to the privacy sheet and its version, stored on your device | Respect your choice | Legal obligation |
2.3Server request logs#
Our backend keeps request logs for security, abuse prevention and diagnosing faults. This processing is essential to running the service and cannot be turned off.
- What is recorded. The time, the part of the service used and the result, your account key when you are signed in, and technical connection details such as your IP address and the type of device or browser. We limit these logs to what those purposes need and protect them as described in clause 9.
- Secrets are never kept. Passwords, sign-in codes and session tokens are not recorded in our logs.
- How long. We keep server logs. After 13 months, the identifiers in them are de-identified in place.
- Who can reach them. Only authorised personnel, for the purposes above.
2.4Analytics and crash reports, by app version#
What the app sends depends on its version. At the date at the top of this page, version 1.0.16 is available through open testing on Google Play and through Apple TestFlight; the main Google Play release is an earlier version.
Versions up to 1.0.15 use Mixpanel and Google Firebase Analytics. From the first launch, without asking, they send usage events (screens viewed, app opens, certain actions) and your account identifier to those two services. They include no crash-reporting service.
From version 1.0.16, Mixpanel and Firebase Analytics are removed, and optional analytics and crash reporting are asked for through a privacy choice. The first time you open the app, a privacy sheet asks you to choose. It has three buttons of equal weight: Accept all, Essential only and Customise. You can change your choice at any time in Settings → Privacy.
- Essential is always on: sign-in, security, fraud and abuse prevention, and our own server records (2.3).
- Analytics & diagnostics is optional. It covers:
- Crash reports, sent to Google Firebase Crashlytics: the crash stack trace, device model and operating-system version.
- Performance measurements (from version 1.0.25), sent to Google Firebase Performance Monitoring: how long screens take to show their content and, on Android, how smoothly they draw, with the device model, operating-system version and app version. They contain no content you write and no account identifier.
- Usage events (for example app opened and screen viewed), sent to our own servers. From version 1.0.16 the app sends usage data to no analytics company.
Nothing optional is collected until you have answered the sheet. If you choose Customise, the analytics switch starts in the on position, and you can turn it off before confirming. If you choose Essential only, or turn the switch off later, the app sends no usage events and crash reporting is switched off.
Data that versions up to 1.0.15 sent to Mixpanel and Firebase Analytics stays with those providers, under our accounts with them. Please update the app when a newer version is available to you.
2.5What we do not collect#
- Precise location. The app never asks for precise (GPS-level) location. It asks only for approximate location, and only when you choose "Use my location" to see jobs near you. Sign-in security records use no GPS and hold no coordinates. Where this policy says "location" it means the city you type in, an approximate city and country worked out from your IP address, or that approximate position if you choose to share it. A backend table can store a precise position. It holds one record, dated October 2025, from before this policy.
- Payment or financial information. See clause 11.
- Health, fitness or biometric data.
- Cross-app tracking or advertising identifiers. The Android app removes the advertising-ID permission, and nothing in the app reads the iOS advertising identifier.
- No sale of personal information, and no sharing of it for cross-context behavioural advertising. The companies listed in clause 3.3 process data for us as service providers. That is not a sale.
- No third-party advertising and no advertising profiles.
2.6Sign-in security events and alerts#
Each time you sign in, we record the time, whether it worked, your IP address, the device you used, and an approximate city and country worked out from the IP address. This is not GPS. We never collect coordinates, and the city and country are only an estimate.
- Why. To keep your account secure and to prevent fraud. If you sign in from a device we have not seen before, or from a country we have not seen before, we alert you.
- You can see them. Your recent sign-ins and devices are shown to you in the Account tab of the app.
- How the location is worked out. On our own servers, offline, using the DB-IP database credited in clause 3.3. Your IP address is not sent to anyone to do this.
- How long. See clause 6. When your account is deleted, your identifiers are removed from these records (clause 8.2).
2.7Notifications and delivery receipts#
We send notifications to your phone (push) and keep a record of them in the app's Notification Centre, so you can find them later. A record holds the type, the title and text, the time, and whether you have read it.
- Delivery and open receipts. The app tells us when a push notification was delivered to your phone and when you opened it, so we can measure whether notifications reach people. The data is the message ID, the event (delivered or opened), your platform, and whether the app was open, in the background or closed. It contains no notification content.
- Who delivers them. Google Firebase Cloud Messaging delivers push notifications. On iPhone, Firebase Cloud Messaging passes them to Apple's push notification service. For devices on older app versions, OneSignal still delivers them (clause 3.3).
- How long we keep them. See clause 6.
- Turning push off. You can stop push notifications in your device's settings. Your notification history in the app remains.
3Who can see your information#
3.1Other members, by design#
- Anyone, signed in or not: what you post in public communities, and your questions and answers.
- Any signed-in member: your name, photo, banner, headline, city, bio, professional and education history, skills, interests, and connection and follower counts.
- Specific people, and us: your direct messages (the recipient, and our authorised personnel only where needed to operate the service, keep members safe or comply with the law); your job applications to roles posted on CHiiRO (the member who posted the role).
- Members of that community: what you post in a private community (3.2).
- Never shown to other members: your email, phone number, date of birth, password, device and technical data, search history, reports you file and your block list.
3.2Private communities#
What is posted in a private community is readable only by that community's members. If you believe you can see content that you should not be able to see, please tell us at hello@chiiro.co (see clause 9.2).
3.3Service providers who process data for us#
| Provider | What it receives | What it does | Where |
|---|---|---|---|
| Microsoft Azure | All application data | Hosts the backend, databases, file storage, the messaging server and this website | API server, main database and messaging (Matrix) server: Central India. File storage (photos, videos, documents) and database diagnostic logs: Canada Central |
| Google Firebase | Up to version 1.0.15: usage events (Firebase Analytics). From version 1.0.16: crash reports, only if you allow them (2.4). From version 1.0.25: performance measurements, only if you allow them (2.4). All versions: the sign-in exchange if you sign in with Google. Newer app versions: your push token and the notification we send you, so it can be delivered (Cloud Messaging) | Analytics (up to 1.0.15); crash diagnostics (Crashlytics, from 1.0.16); performance measurements (Performance Monitoring, from 1.0.25); Google sign-in (Firebase Authentication); push notification delivery (Firebase Cloud Messaging), directly on Android and, on iPhone, relayed to Apple's push notification service | Google's infrastructure; may be outside your country, including the United States |
| Apple Push Notification service | On iPhone only: the notification we send you, passed on by Firebase Cloud Messaging, and your device's push token | Delivers push notifications to iPhones | Apple's infrastructure; may be outside your country, including the United States |
| OneSignal (for devices on older app versions) | Your push token and device details; an internal CHiiRO identifier (not your name or email); the text of each notification it delivers | Sends push notifications to devices on older app versions, for example new comments, likes, connection requests and new chat messages. The OneSignal software also records device information and a location estimated from your IP address. We keep it listed until those older versions are retired | OneSignal's infrastructure; may be outside your country, including the United States |
| Sender.net | Your email address and the email content | Sends transactional email, including one-time sign-in codes | Sender.net's infrastructure |
| Hostinger | Messages you send to our mailbox, and our replies | Hosts our email mailbox and domain mail | Hostinger's infrastructure |
| OpenAI or Microsoft Azure OpenAI Service | The question you type into the AI search assistant | Produces the assistant's answer | The provider's infrastructure |
| LinkedIn (only if you choose it) | The sign-in exchange | LinkedIn sign-in and profile import | LinkedIn's infrastructure |
| Google Analytics (this website only) | Page address and title, referring page, browser and device information, IP address; outside the EEA, the UK, Switzerland and Quebec, a cookie identifier | Measure visits to chiiro.co, in aggregate | Google's infrastructure; may be outside your country, including the United States |
| Mixpanel (versions up to 1.0.15 only) | Usage events, account identifier, device data | Product analytics. Removed from version 1.0.16 | Mixpanel's infrastructure; may be outside your country, including the United States |
| Google Play / Apple App Store | What their own terms cover: app distribution, and ratings or reviews you choose to leave in their stores | Distribute the app; host ratings and reviews | Their terms |
Direct messages are not sent to a third party. They are carried by a Matrix server that RooTree runs itself, on its own virtual machine in our Azure account (Central India).
City and country estimates from your connection. The approximate city and country described in clause 2 are worked out on our own servers, from a copy of the DB-IP “IP to City Lite” database. Your IP address is not sent to DB-IP or to anyone else to do this. IP Geolocation by DB-IP, used under the Creative Commons Attribution 4.0 licence.
Processing agreements. No written data processing agreement is on record with any of the providers above.
3.4Legal reasons#
We may disclose personal information if the law requires it, or if disclosure is necessary to investigate abuse, enforce our Terms of Use or protect someone's safety.
3.5Business transfers#
If CHiiRO or RooTree is acquired, merged or reorganised, personal information may transfer as part of that deal. You will be told before your information becomes subject to a different privacy policy.
4Cookies and similar technologies#
This website uses Google Analytics to measure page views and how visitors arrive. Outside the European Economic Area, the United Kingdom, Switzerland and Quebec it sets two first-party cookies (_ga and _ga_9Q6JV3V68B, two years); inside them it sets none. Google Signals, advertising features and user IDs are off, and the data is kept for 14 months. The site also remembers your light or dark theme choice in your browser's local storage. The Cookie and tracking notice, clause 2, gives the detail and how to refuse the cookies.
The mobile app does not use browser cookies. It stores on your device your sign-in session, the identifiers described in clause 2 and, from version 1.0.16, your privacy choice. From version 1.0.16 the only third-party software that receives data from the app is Firebase (crash reports and, from version 1.0.25, performance measurements when you allow them, Google sign-in if you use it, and push notifications on newer app versions) and, for devices on older app versions, OneSignal (push notifications). Versions up to 1.0.15 also send data to Mixpanel and Firebase Analytics (2.4). The Cookie and tracking notice gives more detail.
5Where your data is held, and international transfers#
| Component | Location |
|---|---|
| Legal entity | Canada |
| API server and main database | Microsoft Azure, Central India |
| Messaging (Matrix) server | Microsoft Azure, Central India |
| File storage (photos, videos, documents) | Microsoft Azure, Canada Central |
| Database diagnostic logs | Microsoft Azure, Canada Central |
| Crash reports, push notifications, email, AI search, sign-in providers | The providers in 3.3 |
| This website | Microsoft Azure Static Web Apps |
If you use CHiiRO from outside India or Canada, your personal information is transferred to and processed in those countries, and by the providers in 3.3 wherever they operate.
Transfer safeguard. We do not yet state a safeguard for transfers out of the EEA and the UK. No executed Standard Contractual Clauses are on record, so we do not claim them.
We plan to move the API server and main database from Central India to Canada Central. This clause will be updated before that happens.
6How long we keep information#
Our rule: we do not hard-delete records, and account deletion is no exception. When you delete your account, you have 30 days to restore it. After that, your identity and profile data are removed from the service and kept in an encrypted archive that the service does not use (clause 8).
| Category | How long | Then |
|---|---|---|
| Account and profile | While your account is open, and for 30 days after you ask to delete it, so you can restore it | Removed from the service and kept in an encrypted archive for 7 years, then de-identified (clause 8) |
| Content you posted | Kept after account deletion | Shown as from "a removed account", with no link to you |
| Direct messages | While your account is open | Messages you sent stay in the conversations of the people you sent them to |
| One-time sign-in codes | Minutes; they expire on use | Your identifiers are removed from them when your account is deleted |
| Notification records, with their delivery and open receipts (clause 2.7) | While your account exists. Your inbox shows a notification for 15 days, then moves it to an archive. How far back you can open the archive depends on your package: Enterprise, without a time limit; Premium, 3 years; Pro, 2 years; Free and Plus, 1 year | When your account is deleted, the personal content of the notifications is erased and only anonymised counts are kept (clause 8.2) |
| Server request and error logs | Kept | Identifiers de-identified in place after 13 months (2.3) |
| Sign-in security events | Kept | Your identifiers are removed from them when your account is deleted, 30 days after you ask |
| Your privacy choice (from 1.0.16) | On your device until you change it or remove the app | — |
| Crash reports (Crashlytics, from 1.0.16) | Google's Crashlytics retention period | Deleted by Google |
| Performance measurements (Firebase Performance Monitoring, from 1.0.25) | Google's Performance Monitoring retention period | Deleted by Google |
| Data sent to Mixpanel and Firebase Analytics by versions up to 1.0.15 | Held by those providers under our accounts | — |
| Reports and moderation records | Kept after the reporter's account is deleted, with the reporter's identity removed | Needed to finish moderation of the person reported |
| Database backups | 7 days | Rotated out |
| Database diagnostic logs | 30 days | Rotated out |
7Your rights#
7.1Everyone#
Wherever you live, you can ask to access, correct, download or delete your personal information. You can edit most of it yourself in the app. From version 1.0.16 you can change your analytics choice at any time in Settings → Privacy. You can turn push notifications on or off in your device's settings. You can see your recent sign-ins and devices in the Account tab, and your notifications in the Notification Centre.
7.2UK and EEA#
You also have the right to restrict processing and to object to processing based on legitimate interests; to data portability; to withdraw consent at any time (withdrawal does not affect processing already done); and not to be subject to decisions based solely on automated processing with legal or similar effect (CHiiRO makes none). You can complain to your data protection authority or, in the UK, the Information Commissioner's Office.
7.3Canada#
Under PIPEDA you can learn what we hold and how it is used and disclosed, access it, challenge its accuracy, withdraw consent (subject to legal or contractual limits), and challenge our compliance: first with us (1.2), then with the Office of the Privacy Commissioner of Canada.
7.4California#
You can ask to know, delete and correct your personal information. We do not sell or "share" it, and we will not treat you differently for exercising a right.
7.5How to ask#
Use the in-app controls where they exist, or email hello@chiiro.co. We respond within 30 days. If a request is complex we may take longer, and we will tell you why.
8Deleting your account#
8.1How#
- In the app: tap your profile photo (top left of Home), then the gear icon to open Settings, then Delete Account at the bottom. The app shows what will be removed. Type
DELETEand confirm. Your account is hidden and you are signed out straight away. It is deleted 30 days later unless you restore it (8.2). - On the web: chiiro.co/data-deletion explains the steps and works without the app.
- By email: write to hello@chiiro.co from the address your account uses. We will act within 30 days and confirm by email.
8.2What deletion does#
CHiiRO is a community where people answer each other's questions. If deleting an account erased everything it ever wrote, the answers other people came for would disappear, and conversations others took part in would have holes. So deletion removes you, not the discussion others contributed to.
Deletion happens in two steps, 30 days apart. We do not hard-delete data at either step.
When you ask.
- Your account is hidden straight away. Other members can no longer find or open your profile, and your posts show “Removed account” instead of your name and photo.
- You are signed out on every device.
- We email you the date on which your account will be deleted.
- You have 30 days to change your mind. Sign in to the app again and choose Restore. Your account comes back as it was. The Restore option is in version 1.0.17 and later; if you do not see it, update the app first.
After 30 days, if you have not restored it, your account is deleted. You can no longer sign in to it or restore it.
- Removed from the service and moved to an encrypted archive: your name, email address, phone number, date of birth and gender; photo, banner, bio and about text; work history, education, skills and interests; uploaded files and documents; connections, follows, votes and bookmarks; search history; saved locations; your sign-in credentials; and the record that links your account to everything else. The archive is not used to run CHiiRO or for any other purpose. It is kept in an encrypted archive for 7 years, then de-identified.
- Direct messages: Messages you sent stay in the conversations of the people you sent them to.
- Kept, permanently detached from you: discussions, comments, questions and answers you posted stay where they are, shown as from "a removed account", with no name, photo or link to you. This cannot be reversed.
- Your devices: push tokens are removed so nothing more is sent to your phone. A record that a device was registered is kept, without the token.
- Notifications: the personal content of your notifications (titles, text and links) is erased. Only anonymised counts are kept, for example how many notifications of a type were delivered.
- Sign-in security events: kept, with your account key, IP address, user agent, device fingerprint and approximate city and country removed when your account is deleted. Only the shape of each event remains: what happened, whether it succeeded, and when.
- Server request logs are kept when you delete your account (2.3); the identifiers in them are de-identified in place after 13 months.
- Reports you filed: kept with your identity removed, so moderation can finish.
One limit we cannot remove. Free text can identify its author even after every identifier is gone. A post that names a company, a city and a year may point to the person who wrote it. If you want a specific post gone, delete it before you delete your account.
Asking for complete erasure. If you want the archived copy of your data erased as well, email hello@chiiro.co from the address your account used. We respond within 30 days (7.5) and will tell you if the law requires us to keep anything.
9How we protect your information#
9.1Our safeguards#
We protect your information with administrative, technical and organisational safeguards suited to how sensitive it is. Depending on the type of information, these include:
- encryption of information in transit between the app, this website and our servers;
- encryption of sensitive account information when stored, and one-way hashing of passwords;
- access controls that limit who can reach our systems and your information, with that access logged; and
- regular review and improvement of these measures.
Content you choose to post publicly is visible to other members by design. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
9.2Security questions#
If you have a security question or believe you have found a vulnerability, contact hello@chiiro.co. Please do not include passwords or sign-in codes in your message.
10Children#
CHiiRO is not for anyone under 16. We do not knowingly collect personal information from anyone under 16. If you believe someone under 16 has given us information, write to hello@chiiro.co and we will delete it. The app asks for a date of birth but does not currently enforce the minimum age against it.
11Payments#
CHiiRO does not charge members and has never taken a payment. There are no in-app purchases and no payment gateway in use. We collect no card numbers, bank details or billing addresses. If paid features are ever introduced, this policy will be updated before any payment is taken.
12AI-generated content#
Much of the content in CHiiRO (discussions, questions, answers and comments), and many of the profiles that appear to write it, were generated by AI. These are our "Inspired Synth" personas, created as seed material. They are not people. The app marks their content with a SYNTH label. The Disclosures page gives the full account, and the AI and legal notice applies to everything on CHiiRO.
13Changes to this policy#
We will post changes here and update the date at the top. If a change materially affects your rights, we will tell you in the app or by email before it takes effect.
14Contact#
hello@chiiro.co · RooTree Analytic Inc., a corporation incorporated in Canada. If you are in Canada and are not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada. In the EEA or UK, you can complain to your local data protection authority.