LIBCOMPLUS — PRIVACY POLICY

Version 1.8 — 12 October 2026 For users already registered, it applies 30 days after they are notified.

English courtesy translation. The French version prevails (section 15).

In short.

- Your messages are encrypted in transit and encrypted at rest on our servers. To be translated, a message is decrypted in memory, for the time of the translation only.

- We do not sell your data.

- We do not use your messages for advertising or to train artificial intelligence models.

- You can export or delete your data from the app.

Contents

1. Controller and contacts
2. Data we process
3. Purposes and legal bases
4. Recipients and processors
5. Transfers outside the European Union
6. Security and encryption
7. Retention periods
8. Your rights
9. Account deletion
10. Minors and content safety
11. Automated decisions
12. Cookies, local storage and usage measurement
13. Advertising
14. Changes to this Policy
15. Reference language

1. Controller and contacts

• Controller: AENSSecurX LLC, a limited liability company of the Commonwealth of Pennsylvania (United States), registration number 0014745325, reachable in writing at privacy@libcomplus.com, doing business as LibComPlus. Legal representative: Adeoye de Souza.
• Establishment: LibComPlus has no establishment in the European Union.
• Designated representative in the Union (GDPR, art. 27): contact details will be published on this page as soon as the representative is designated. Until then, write to privacy@libcomplus.com or legal@libcomplus.com.
• Data protection officer: Adeoye de Souza, privacy@libcomplus.com.
• Contact us, by e-mail only: support support@libcomplus.com — legal legal@libcomplus.com — child safety and authorities safety@libcomplus.com.

This Policy applies to the LibComPlus application (Android, iPhone, web app) and to the libcomplus.com website.

2. Data we process

2.1 Account and profile

• Required: mobile phone number (your identifier), first name, password (stored as a hash), declaration that you meet the minimum age, communication and interface languages.
• Optional: last name, photo, bio (translated automatically), e-mail address (account recovery, invoices).

2.2 Phone number verification

To prove the number is yours:

• by missed call, SMS or WhatsApp: your number is sent to our verification provider, which calls you or sends you a code. We do not read your phone's call log or SMS;
• by a Mobile Money payment you make from that number: the payment operator tells us the number that paid.

Each attempt is logged (date, country, channel, provider, result) to prevent abuse. The number appears in clear only during verification; it is then replaced by a hash. The country of your verified number may be used to adjust the price of certain services (section 3).

2.3 Messages, calls and media

• Messages (text, voice, media, scheduled messages): stored encrypted on our servers so that you and your contacts can retrieve them, until they are deleted.
• Calls: sound and video pass through our calling infrastructure. They are not recorded. Call subtitles are used for live display and are deleted at the latest a few hours later.
• Translations and voices: translations and synthetic voices may be cached, encrypted, to be served again.

2.4 Trad and translator history

The text you translate, its translation, the languages and the date are stored encrypted so that you can find them on your devices, until you clear the history. A translated photo is processed to read its text.

2.5 LibDoc and meetings

• Documents: the imported file, its text, passages, search index, reading voices, translations, exports and photographed pages are stored in a private space linked to your account until you delete the document. Deletion erases them within about fifteen minutes; the pages of a notebook never completed are erased after 7 days.
• Share links: private, opened only by a signed-in person who receives them from you. They expire after 7 days by default, 30 days at most. We count openings.
• Meetings:
• the audio is transcribed;
• in Standard mode, it is kept for replay, then erased at the earliest 30 days after the meeting, always after at least 7 days' notice, unless you choose to keep it (within your storage space);
• in Confidential mode, it is never stored on our servers;
• transcripts and minutes remain until deleted.

2.6 Explore: videos, lives, channels and Moments

• Videos: the file you upload, its playback versions, audio track, thumbnails, transcript, subtitles and dubbed tracks.
• A published video is kept until you delete it, within your storage space.
• The original file is deleted 30 days after publication.
• Lives: audio and video streams of the host and co-hosts, translated subtitles and voices, recording and replay if enabled, chat messages and their translations, gifts, hearts, number of viewers.
• Public interactions: likes, comments, follows of a creator or channel, memberships, views (counted, de-duplicated over one hour).
• Public content: it is visible to the people covered by the visibility you chose (public, members, followers), and may be translated, subtitled or dubbed for them.

2.7 Marketplace and shops

Shop and product listings, translations of listings, and the shop location if you save it ("Use my location").

• That location is visible to people who can see the shop.
• It is never tracked.
• It is deleted with the shop or at your request ("Remove location").

When you search for products near you, your location is used only to calculate distances and is not stored.

2.8 Shared location

You can share a place or your live location in a conversation, always by an action of your own.

• Shared places: stored encrypted, accessible only to participants.
• Live location: only the latest position is kept, with no history, and it is deleted when sharing ends.
• A place's address is obtained from your device's geocoding service (Google on Android, Apple on iPhone) or, in the web app, from OpenStreetMap, which also provides map tiles.

2.9 Address book

If you allow it, the app reads the numbers in your address book.

• Each number is turned on your phone into a hash before anything is sent. Your contacts' names stay on your phone.
• We keep these hashes, encrypted again, to show which contacts use LibComPlus and to tell you when they join.
• A hash is still personal data: someone who already knows a number can check whether it matches.

2.10 Invitations and referral

• Invitations: an invitation is sent from your own app (SMS, WhatsApp, Telegram, e-mail). For an invitation to a specific person, we record a hash of their number, the language, the channel and a link valid for 30 days.
• Referral: who invited you, your referees, their qualifying purchases and your rewards.
• Source of your sign-up: if you arrived through a campaign link, a libcomplus.com/go/… short link, an ambassador's link or the Google Play listing, we store with your account what that link carried (network, campaign, content, ambassador code, short link), the first and last links received, and the sign-up platform (web, Android). Before sign-up, this information stays on your device for at most 30 days. Clicks on our short links are only counted per day, with no data about you. We use no third-party cookies and no advertising identifier.

2.11 Purchases, tokens and earnings

• Purchases: purchase and token debit history, invoices, amounts, taxes, payment method used (without card number or Mobile Money credentials), order identifier sent by an app store.
• Creator earnings: gifts, memberships, tickets and sales received, commissions, maturation, reversals.
• Creator identity verification (KYC): before any cash withdrawal, name, date of birth, identity document and payout method (for example a Mobile Money number). The identity document is checked manually by our team.

2.12 Automated assistants and support

• If you write to a person or shop using an automated assistant, or use LibComPlus help, your message (transcribed if spoken) and the necessary context are processed by our artificial intelligence providers on our behalf.
• In a conversation between two people who speak the same language, an assistant reads messages only with both people's agreement.
• When you contact support, we process your message and any technical information you provide.

2.13 Reports and moderation

Reports received or made, snapshot of the reported content, decisions and their reasons, appeals, results of the automated analysis of images and videos, and items placed under legal hold (section 10).

2.14 Technical and usage data

• Device: model, system, app version, language, time zone, network type, carrier, IP address, notification identifier.
• Technical logs: errors and crashes. They never contain the text of your messages or what is said during a call.
• Internal usage measurement (telemetry): screens and features used, durations, technical events. See section 12.
• Sign-ins: each time you open the app after being away, we record the date, the platform (web, Android, iPhone), the app version, the type of device and browser, your truncated IP address (the last group of digits is erased) and the network country.
• Presence: the last moment the app showed signs of life, and whether you are "online" (less than two minutes). Your contacts only see this according to your privacy settings. We never know your location: only the country of your number or network.

2.15 LibComPlus communications

• In-app announcements (new terms, important information): we record that an announcement was shown to you, that you opened it and that you tapped "Got it".
• News and offers: your choices (by e-mail, by notification), off until you turn them on, with their date, their origin (app or unsubscribe link) and the version of the wording shown, so that we can prove your consent.
• E-mails: for each e-mail we send you, its delivery, opening, any click or rejection, as reported by our sending provider.

2.16 Access by our team

• Only authorised members of our team access data, according to their role (support, moderation, finance, security, administration), with two-factor authentication.
• An account record (account identity, plan, balances, verifications, sign-ins, purchases, reports, sanctions, public content) only opens for a specific reason (support, investigation, report, legal obligation), recorded in an access log that can be neither changed nor erased.
• The content of your private messages never appears in it. A private message is only viewed if it has been reported or is under legal hold, from the moderation tool.
• Exporting an account's data by our team requires the approval of two authorised people.

3. Purposes and legal bases

We do not sell your personal data. We do not use the content of your messages, calls or documents for advertising, profiling or model training.

4. Recipients and processors

Your contacts and the public see what you send them or publish, and your name and photo according to your settings.

Our processors process data on our behalf, on our instructions, and are contractually bound to protect it:

An app store (Google Play, App Store) also processes your data as a separate controller for purchases you make there, under its own policy.

Authorities. We may disclose data where the law requires, at the request of a competent authority, or to protect a person's safety, in particular a child's (section 10).

5. Transfers outside the European Union

Some providers process data outside the European Union, in particular in the United States, Nigeria and the countries of their global network. These transfers are covered by:

• the European Commission's standard contractual clauses, or the provider's certification under the EU–US Data Privacy Framework where it exists;
• supplementary measures: encryption in transit and at rest, minimisation of the data sent;
• EU hosting wherever possible (Supabase, Microsoft, Hetzner, Sentry, Stripe Ireland, PawaPay Estonia).

You can obtain a copy of the safeguards by writing to privacy@libcomplus.com.

6. Security and encryption

To translate a message, our servers must read it for the time of the translation. We therefore apply, to all conversations:

What LibComPlus does not encrypt beyond the host: LibDoc documents, videos and public media, which are protected by our providers' disk encryption and access control.

Our translation and artificial intelligence providers process content on our behalf. They do not use it to train their models and do not keep it beyond what their terms provide for security and abuse prevention.

We also protect access (restricted rights, logging of sensitive access) and will notify you and the competent authority of any data breach posing a risk, as required by law.

7. Retention periods

8. Your rights

You have the rights of access, rectification, erasure, restriction, portability, objection (in particular to processing based on legitimate interest), withdrawal of consent at any time, and the right to give instructions on what happens to your data after your death.

• Export your data: Settings › Export my data.
• Rectification: from your profile.
• Deletion: Settings › Delete my account (section 9).
• Contacts and location: withdraw your consent in the app or phone settings.
• News and offers: turn them off in Settings, then Notifications, or tap "Unsubscribe" at the bottom of any news e-mail.
• Any other right: privacy@libcomplus.com. We may ask you to prove your identity. We reply within one month, extendable by two months for complex requests.

Complaint. You may lodge a complaint with the data protection authority of your country of residence; in France, the CNIL (www.cnil.fr).

9. Account deletion

You can delete your account in the app (Settings › Delete my account), on app.libcomplus.com, or, if you can no longer sign in, by writing to privacy@libcomplus.com (we then check that the request comes from you). The procedure is described at libcomplus.com/suppression-compte.

Deletion becomes final 30 days after the request, a period during which you can cancel it. It results in:

• deletion of your profile, documents, videos, live recordings and files linked to your account;
• deletion of messages you sent in a group or channel. Those in a one-to-one conversation are no longer linked to your account but remain with your contact until they delete them;
• loss of your unused tokens;
• the end of your card subscription, with no renewal after your request (an app-store subscription is cancelled in the app store).

We keep what the law requires (invoices and payments for 7 years) and items under legal hold (section 10). While a child-protection case is open, the account concerned is not deleted.

10. Minors and content safety

Age. The Services are reserved for people aged 16 and over, age declared at sign-up. Broadcasting a live, receiving gifts and seeing advertising are reserved for adults. We do not knowingly collect data from people under 16. To report such an account: in the app, or at safety@libcomplus.com.

Automated analysis of images and videos. Images and videos shared (conversations, groups, Moments, channels, profiles, shops, Explore) are analysed automatically by our servers and providers, with comparison against content already rejected, to detect manifestly unlawful content, in particular child sexual abuse, extreme violence and non-consensual sexual content.

• In conversations and groups, a media item is shown only after this analysis.
• Detected content may be reviewed by an authorised member of our team.
• This analysis is never used for advertising, profiling or model training.
• Legal basis: legal obligation and compelling legitimate interest (GDPR, art. 6.1.c and 6.1.f).

Legal hold. When a child-protection case is opened, the content and account concerned are preserved as evidence, even if their author deletes them. Access is restricted to authorised people and logged. Items reported to the authorities are kept at least one year after the report.

11. Automated decisions

Some decisions are taken by automated systems:

• blocking an image or video detected as manifestly unlawful;
• anti-abuse limits (number of verifications, messages, uploads);
• adjusting the price of certain services to your plan and the country of your verified number. The price is always shown before the action and never exceeds the reference price.

You can challenge a moderation decision and obtain a review by a person ("Challenge" in the app, or support@libcomplus.com), and ask for an explanation of any automated decision concerning you at privacy@libcomplus.com.

12. Cookies, local storage and usage measurement

• Essential: the web app and website use your browser's local storage to keep your session, remember your preferences (language, theme) and support offline mode. These do not require your consent.
• Source of a link: when you arrive through a campaign or ambassador link, the website and web app keep what the link carried in your browser's local storage (30 days at most), to attach it to your sign-up. No cookies, no third-party service.
• Usage measurement: we measure the use of features to fix errors and improve the Services (internal telemetry, kept 90 days). On Android, the app also uses Firebase Analytics (Google) for aggregated usage statistics (opens, sessions, versions), without advertising identifier.
• No advertising trackers and no device advertising identifier are used.

13. Advertising

Advertisements may appear in public areas of Explore, labelled as such.

• None in conversations, calls or documents.
• None for a person whose adulthood has not been established.
• Targeting is limited to language and country. It never uses the content of your messages, calls or documents, and no advertising profile is created.
• We count impressions and clicks (de-duplicated) to bill the advertiser, without passing your identity on to them.

14. Changes to this Policy

For a significant change, we inform you in the app at least 30 days before it takes effect. The version date appears at the top of this Policy.

15. Reference language

This Policy is published in several languages. The French version prevails in the event of any discrepancy, subject to mandatory rules of your country of residence.

LibComPlus — Privacy Policy — Version 1.8 — 12/10/2026