Last Revised on May 21, 2018
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.
EFFECTIVE DATE: May 25, 2018
WHO WE ARE
INFORMATION WE COLLECT
COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES
HOW WE USE INFORMATION
HOW WE SHARE INFORMATION
CROSS-BORDER DATA TRANSFERS
RESIDENTS OF CALIFORNIA
HOW WE PROTECT YOUR INFORMATION
HOW LONG WE RETAIN YOUR INFORMATION
HOW TO CONTACT US
The Black Church, St. Mary’s Place
Dublin 7, D07 P4AX
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.
You choose to give us certain information when using our services. This includes:
When you create an account, you provide us with at least your login credentials, as well as some details necessary for the service to work. These are your name, gender, date of birth, location, profile photo on Facebook, pages you liked on Facebook and list of your Facebook friends who use Smopin. We used to gather your school and work information from Facebook, but we do not gather them from Facebook anymore.
After creating your account, you can share with us additional information, such as details on your work, school, personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera, photo album or Facebook photos. Please also know that we DO NOT collect all your photos available in your device or Facebook profile. We only store your profile picture on your Facebook account and photos that you manually upload to your Smopin profile. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact our customer service team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
In addition to the information you provide us directly, we receive information about you from others, including:
Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
You may be able to use your social media login (such as Facebook Login) to create and log into your Smopin account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.
We may receive info about you from our partners, for instance where Smopin ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
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:
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
We may collect information from and about the device(s) you use to access our services, including:
hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
information on your wireless and mobile network connection, like your service provider and signal strength;
information on device sensors such as accelerometers, gyroscopes and compasses.
information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).
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.
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.
Create and manage your account
Provide you with customer support and respond to your requests
Complete your transactions
Communicate with you about our services, including order management and billing
Analyze your profile and that of other users to recommend meaningful connections
Show users’ profiles to one another
Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
Register you and display your profile on new Smopin features and apps
Administer your account on these new features and apps
Administer sweepstakes, contests, discounts or other offers
Develop, display and track content and advertising tailored to your interests on our services and other sites
Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
Administer focus groups and surveys
Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
Address ongoing or alleged misbehavior on and off-platform
Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent against recurrences
Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:
Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
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.
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.
We want you to be in control of your information, so we have provided you with the following tools:
Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer service team for help by emailing here. (email@example.com)
Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as access to photo albums and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
Deletion. You can delete your account by using the corresponding functionality directly on the service (the app). Keep in mind that, to delete your account you need to tap on “Delete Account” button in Profile page on Smopin. If you only delete the app without deleting your account, your profile will cease to exist and will be still visible to other users.
We want you to be aware of your privacy rights. Here are a few key points to remember:
Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request by sending us an email to firstname.lastname@example.org
Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us by sending us an email to email@example.com
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.
Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
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 firstname.lastname@example.org . 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.
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 email@example.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)
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:
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);
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
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.
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 firstname.lastname@example.org
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.
The Black Church, St. Mary’s Place
Dublin 7, D07 P4AX