Owner address: 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
Owner contact email: email@example.com
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.
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
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.
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.
Appnext (Appnext Ltd.)
Appnext is an advertising service provided by Appnext Ltd.
Personal Data collected: Cookies and Usage Data.
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.
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.
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.
DigitalOcean (DigitalOcean Inc.)
DigitalOcean is a hosting service provided by DigitalOcean Inc.
Location - based interactions
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).
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 .
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.
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.
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.
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
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
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.
Purposes and Lawful Bases to Process Your Personal Data
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.
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:
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.
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.
The individual using SFriends who, unless otherwise specified, coincides with the Personal Data Subject.
The natural person to whom the Personal Data refers.
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.
Cookies Small piece of data stored in the User's device.
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).
Last updated: June 29, 2018