Privacy Policy of SFriends

This Privacy Policy (“ Privacy Policy ”) describes how EonApps Limited and its related companies (“ Owner ”, “we”, “us”, “our”) collect, use and share personal information of consumer users of th e SFriends website, https://addsnapchatfriends.com (the “Website”) , and mobile application ( with the Website, collectively, “SFriends”) .

Owner

EonApps Limited
Owner address: 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
Owner contact email: legal@eonapps-limited.com

Types of Data collected

We may collect Personal Data as follows:

Identity Data includes first name, last name, username or similar identifier,photo,date of birth, country of residence and gender.
Contact Data includes email addressand Snapchat, Kik, and Instagram usernames.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Financial Data includes bank account and payment card details.
Usage Data includes information automatically collected through SFriends (or third - party services employed in SFriends), about how you use SFriends , products and services. This can include the following information: Cookies, the IP addresses or domain names of the computers utilized by the Users who use SFriends, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server , the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within SFriends ) and the details about the path followed within SFriends with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User 's IT environment.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Personal Data is freely provided by the User, or, in case of Usage Data, collected automatically when using SFriends.
Unless specified otherwise, all Personal Data requested by SFriends is required , and your failure to provide such Personal Data may make it impossible for SFriends to provide its services. In cases where SFriends expressly states that Personal Data is optional , Users may choose not to share such Personal Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies or other tracking tools by SFriends or by the owners of third - party services used by SFriends serves the purpose of providing the Service requested by the User, in addition to any other purposes described in th is Privacy Policy and in the Cookie Policy, if available. Users are responsible for any third - party Personal Data obtained, published or shared through SFriends and confirm that they have the third party's consent to provide the Personal Data to the Owner.

Mode and place of processing Personal Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases,the Personal Data may be accessible to certain types of persons in charge, involved with the operation of SFriends (administration, sales, marketing, legal, system administration) or external parties(such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place of Processing

The Personal Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User’s Personal Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users should review the section of this Privacy Policy containing details about the processing of Personal Data.

The purposes of processing

Personal Data is collected to allow the Owner to provide SFriends and related services, as well as for the following purposes detailed below: Advertising, Contacting the User, Handling Payments, Hosting and backend infrastructure, Location - based interactions, Managing contacts and sending messages, Registration and authentication, and Social features.

  • Advertising

  • We may use your User Profile Data for advertising communication purposes in the form of banners and other advertisements displayed for you on SFriends. The third-party services listed below may use Cookies to identify Users or they may use the behavioral retargeting, i.e., displaying ads tailored to the User’s interests and behavior, including behavior and interests detected from outside of SFriends. For more information, please check the privacy policies of the relevant third-party service. In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

    AdMob (AdMob Google Inc.)

    AdMob is an advertising service provided by AdMob Google Inc.
    In order to understand Google's use of Data, consult Google's partner policy.
    Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
    Place of processing: US – Privacy PolicyOptOut.

    Appnext (Appnext Ltd.)

    Appnext is an advertising service provided by Appnext Ltd.
    Personal Data collected: Cookies and Usage Data.
    Place of processing: British Virgin Islands – Privacy Policy.

  • Contacting the User

    Mailing list or newsletter (SFriends)

    list of those who may receive email messages containing information of commercial or promotional nature concerning SFriends. Your email address might also be added to this list as a result of signing up to SFriends or after making a purchase.
    Personal Data collected: Identity Data.

  • Handling payments

    SFriends collects Financial Data to process payments by credit card, bank transfer or other means. To ensure greater security, SFriends shares only the information necessary to execute the transaction with the third-party financial intermediaries handling the transaction.
    Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
    Google Wallet (Google Inc.) Google Wallet is a payment service provided by Google Inc., which allows Users to make online payments using their Google credentials.
    Personal Data collected: Financial Data and data as specified in the Privacy Policy of the third-party service.
    Place of processing: US – Privacy Policy.

  • Hosting and backend infrastructure

    This type of third-party service has the purpose of hosting data and files that enable SFriends to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of SFriends.
    Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
    mLab (ObjectLabs Corporation)
    mLab is a hosting and backend service provided by ObjectLabs Corporation.
    Personal Data collected: various types of Data as specified in the Privacy Policy of the service.
    Place of processing: US – Privacy Policy.
    DigitalOcean (DigitalOcean Inc.)
    DigitalOcean is a hosting service provided by DigitalOcean Inc.
    Personal Data collected: various types of Data as specified in the Privacy Policy of the service.
    Place of processing: US – Privacy Policy.

  • Location - based interactions

    Geolocation (SFriends)
    SFriends may collect, use, and share User location Data in order to provide location - based services.
    Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by SFriends. Personal Data collected: location (Usage Data).

  • Managing contacts and sending messages

    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
    Mailjet (SAS Mailjet)
    Mailjet is an email address management and message sending service provided by SAS Mailjet.
    Personal Data collected: email address (Contact Data).
    Place of processing: France – Privacy Policy.

  • Registration and authentication

    By registering or authenticating, Users allow SFriends to identify them and give them access to dedicated services. Third parties may also provide registration and authentication services. In this case, SFriends will be able to access some Personal Data stored by these third - party services for registration or identification purposes.
    Direct registration (SFriends)
    The User registers by filling out the registration form and providing the Personal Data directly to SFriends.
    Personal Data collected: Identity, Contact, and Profile Data .

  • Social features

    Public profile (SFriends)
    Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with SFriends.
    Personal Data collected: Identity and Contact Data.

    Inviting and suggesting friends (SFriends)
    SFriends may use the Personal Data provided to allow Users to invite their friends, for example, through the address book, if access has been provided, and to suggest friends or connections inside it.
    Personal Data collected: Identity and Contact Data.

  • Further information about Personal Data

  • The Service is not directed to children under the age of 13
    SFriends is not intended for children under 13 years of age. No one under age 13 may provide any information on or through SFriends. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on SFriends or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

  • Children in the European Union
    If you are in the European Union, you must be at least 16 years old to use SFriends. We do not knowingly collect personal information from children under 16. By using SFriends, you declare yourself to be an adult as defined by the laws of your country of residence. If you are under 16, do not use or provide any information on this SFriends or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.

    Under no circumstances, however, shall persons under the age of 16 in the European Union use SFriends. If you believe we might have any information from or about a child under 16, please contact us.

  • Push notifications

    SFriends may send push notifications to the User.

  • Unique device identification

    SFriends may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

  • User identification via a universally unique identifier (UUID)

    SFriends may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this SFriends, it persists between SFriends launches and updates, but it is lost when the User deletes the SFriends mobile application. A reinstall generates a new UUID.

Cookie Policy

SFriends uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action
The User's Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of SFriends or the related services. The User acknowledges and agrees that the Owner may be required to reveal Personal Data in response to requests by public authorities.
Additional information about User's Personal Data
In addition to the information contained in this Privacy Policy, SFriends may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, SFriends and any third - party services may collect files that record interaction with SFriends (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this Privacy Policy.
How “Do Not Track” requests are handled
SFriends does not support “Do Not Track” requests.
To determine whether any of the third - party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Information choices and changes
Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. You may send requests about Personal Data to our contact information above. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Data. You can typically remove and reject Cookies from SFriends with your browser settings. Many browsers are set to accept Cookies until you change your settings. If you remove or reject our Cookies, it could affect how SFriends works for you.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of SFriends that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.
Changes to this Privacy Policy
The Owner reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and possibly within SFriends and/or - as far as technically and legally feasible - sending a notice to Users via any Contact Data available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

For Individuals in the European Union (“EU”) – General Data Protection Regulation (“GDPR”)

This Privacy Policy describes how the Owner collects, uses and shares your personal information. If you are in the EU, you are subject to the GDPR, and the following terms also apply to you. The Owner is the Data Controller and responsible for your Personal Data.

Purposes and Lawful Bases to Process Your Personal Data

This Privacy Policy describes the Personal Data we collect from you and the lawful bases for its collection. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need it to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by contacting us. Specifically, we have a purpose and lawful basis for processing each type of Personal Data as described in this Privacy Policy, which are as follows:

  1. The purpose for collecting your Identity and Contact Data is to register you as a new user, and the lawful basis is the performance of a contract with you.
  2. The purpose for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data is to process and deliver your purchases, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
  3. The purpose for collecting your Identity, Contact, Profile, and Marketing and Communications Data is to manage a relationship with you, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
  4. The purpose for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data is to enable you to partake in a contest, competition or complete a survey, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business).
  5. The purpose for collecting your Identity, Contact, and Technical Data is to administer and protect our business and SFriends, and the lawful basis is that it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
  6. The purpose for collecting your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data is to deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, and the lawful basis is that it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
  7. The purpose for collecting Technical and Usage Data is to use data analytics to improve SFriends, marketing, customer relationships and experiences, and the lawful basis is that it is necessary for our legitimate interests (to define types of customers for our products and services, to keep our service updated and relevant, to develop our business and to inform our marketing strategy).
  8. The purpose for collecting Identity, Contact, Profile, Usage, and Technical Data is to make suggestions and recommendations to you about goods or services that may be of interest to you, and the lawful basis is that it is necessary for legitimate interests (to develop our products/services and grow our business).

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out forth in this Privacy Policy.

We may have to share your Personal Data with the parties and for the purposes described in this Privacy Policy. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS UNDER THE GDPR

Under certain circumstances, EU residents have rights under data protection laws in relation to their Personal Data. If you are an EU resident, you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Personal Data's accuracy; (b) where our use of the Personal Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Definitions and legal references

Personal Data
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
User
The individual using SFriends who, unless otherwise specified, coincides with the Personal Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor) The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this Privacy Policy.
Data Controller (or Owner) The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of SFriends. The Personal Data Controller, unless otherwise specified, is the Owner of SFriends.
SFriends The means by which the Personal Data of the User is collected and processed.
Service The service provided by SFriends as described in the relative terms (if available) and on this site/application.
European Union (or EU) Unless otherwise specified, all references made within this Privacy Policy to the European Union include all current member states to the European Union and the European Economic Area.
Cookies Small piece of data stored in the User's device.

Legal information This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This Privacy Policy relates solely to SFriends, if not stated otherwise within this Privacy Policy.

Last updated: June 29, 2018