Smopin Privacy Policy

Last Revised on May 21, 2018

Welcome to Smopin’s Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy applies beginning May 25, 2018.

EFFECTIVE DATE: May 25, 2018

  1. WHO WE ARE

  2. WHERE THIS PRIVACY POLICY APPLIES

  3. INFORMATION WE COLLECT

  4. COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

  5. HOW WE USE INFORMATION

  6. HOW WE SHARE INFORMATION

  7. CROSS-BORDER DATA TRANSFERS

  8. YOUR RIGHTS

  9. RESIDENTS OF CALIFORNIA

  10. HOW WE PROTECT YOUR INFORMATION

  11. HOW LONG WE RETAIN YOUR INFORMATION

  12. CHILDREN’S PRIVACY

  13. PRIVACY POLICY CHANGES

  14. HOW TO CONTACT US



1. WHO WE ARE

The company that is responsible for your information under this Privacy Policy (the “data controller”) is:

SMOPIN LIMITED
The Black Church, St. Mary’s Place
Dublin 7, D07 P4AX
Ireland

2. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services operated by Smopin. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy -- not this Privacy Policy -- applies.



3. INFORMATION WE COLLECT

It is important for you to understand that we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

Information collected when you use our services

When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

4. COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Smopin, do not currently respond to DNT signals.



5. HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with examples.

To administer your account and provide our services to you

To help you connect with other users

To ensure a consistent experience across your devices

To provide new Smopin services to you

To serve you relevant offers and ads

To improve our services and develop new ones

To prevent, detect and fight fraud or other illegal or unauthorized activities

To ensure legal compliance

To process your information as described above, we rely on the following legal bases:

6. HOW WE SHARE INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services and in some cases, legal authorities. Read on for more details about how your information is shared with others.

You share information with other users when you voluntarily disclose information on the service (including your public profile and your location’s distance to other users). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

We may also share information with partners who distribute and assist us in advertising our services by keeping our users’ identity disclosed. For instance, we may share limited information on you in hashed, non-human readable form or in a way that your identity remained undisclosed to advertising partners.

We may share your Facebook ID or your email with Facebook for remarketing purposes on Facebook’s platforms such as Facebook, Instagram and Messenger.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

7. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

8. YOUR RIGHTS

We want you to be in control of your information, so we have provided you with the following tools:

We want you to be aware of your privacy rights. Here are a few key points to remember:

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth. Additionally, if you deleted your account, the data you requested may be deleted.

9. RESIDENTS OF CALIFORNIA

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to wave@smopin.com . Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

10. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately wave@smopin.com

In order to ensure that our systems and your information are protected against unauthorized access, theft and loss, we are also using SSL Certificate (click here for more info) to protect our database and Amazon’s Cognito Service’s authentication feature when users log in to their accounts. (click here for more info)



11. HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of 40 days following account deletion. During this period, account information will be retained on our live database and backups although the account will of course not be visible to other users on the services (the app) anymore. At the end of 40 days, your account will be completely erased from our backups as well.

In practice, we delete or anonymize all your information that can directly identify you such as your name, email, photos, location, work info, education info, chats etc. upon deletion of your account, unless:

  1. we must keep it to comply with applicable law (for instance, some “traffic data” may be kept for one year to comply with statutory data retention obligations);

  2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

  4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

12. Minors’ PRIVACY

Our services are restricted to users who are 16 years of age or older. We do not permit users under the age of 16 on our platform and we do not knowingly collect personal information from anyone under the age of 16. If you suspect that a user is under the age of 16, please use the reporting mechanism available through the service and email us a screenshot of that profile to wave@smopin.com

13. PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any major material change takes effect so that you will have time to review the changes. Please always download our app Smopin’s latest version to be notified on time.

14. HOW TO CONTACT US

If you have questions about this Privacy Policy, here’s how you can reach us:

Online: wave@smopin.com

By post:
SMOPIN LIMITED
The Black Church, St. Mary’s Place
Dublin 7, D07 P4AX
Ireland