Privacy Policy
01 July, 2023
Welcome to the Privacy Policy of SozialMe
This Privacy Policy applies to our SozialMe Application, as well as to our SozialMe website and our social media
platforms. Herein after we refer to all of these as our “services” in this Privacy Policy.
Collecting Information
At SozialMe, we collect information about your use of our services such as access logs, as well as information from
third parties, like when you access our services through your social media account or when you upload information
from your social media account to complete your profile.
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 phone number and email address, as well as some
basic details necessary for the service to work, such as your gender, date of birth, location.
-
You also share additional information with us, such as details on your bio such as your interests and your
interests, as well as content such as photos.
- If you contact our customer care team, we collect the information you give us during the interaction.
-
If you share with us information about other people (for example, if you use contact details of a friend for a
given feature), we process this information on your behalf in order to complete your request.
-
Of course, we also process your chats with other members as well as the content you upload to operate and
secure the services, and to keep our community safe.
In addition to the information you may provide us directly, we receive information about you from others,
including:
-
Members: Members may provide information about you as they use our
services, for instance as they interact with you on SozialMe or if they submit a report involving you.
-
Social Media:You may decide to share information with us through your
social media account, for instance if you decide to create and log into your account via your social media or
other account (e.g., Facebook, Google or Apple) or to upload onto our services information such as photos from
one of your social media accounts (e.g., Instagram or Spotify).
When you use our services, this generates technical data 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.
-
Usage Information: Using the services generates data about your activity
on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions
taken, information shown to you, referring webpages address and ads that you interacted with) and your
interactions with other members (e.g., members you connect and interact with, and when you matched and
exchanged messages with them).
-
Device information:We 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, apps settings and characteristics, app crashes, advertising IDs and identifiers associated with cookies
or other technologies that may uniquely identify a device or browser.
-
Information collected by cookies and similar technologies: We use and
may allow others to use cookies and similar technologies (e.g., web beacons, pixels, SDKs) to recognize you
and/or your device(s).
-
Precise geolocation data:We are obliged at SozialMe to collect your
precise geolocation (latitude and longitude) from your device. The collection of your geolocation stops during
a period of inactivity, for your personal safety reasons.
Please note that the main reason we use your information is to deliver and improve our services. Additionally, we
use your info to help keep you and our community safe. The following are the main reasons we use your information.
To administer your account and provide our services to you
- Create and manage your account
- Provide you with customer support and respond to your requests
- Communicate with you about our services
To help you connect with other users
-
Show you on our mapping services and show other members to you on the map, depending on their visibility modes.
- Show members’ profiles to one another via our services
- Enable members to connect with others.
To provide new updates/versions of SozialMe to you
- Register you and display your profile on new later SozialMe versions
- Administer your account on these new features and apps
To improve our services and develop new ones
- Review interactions with customer care teams to improve our quality of service
- Understand how members typically use the services to improve them
- Develop new features and services
To prevent, detect and fight fraud
- Find and address ongoing, suspected or alleged violations of our Terms and Community Guidelines
- Better understand violations of our Terms and Community Guidelines
- Retain data related to violations of Terms and Community Guidelines
- Enforce or exercise our rights, for example our rights set out in our Terms and Community Guidelines
-
Communicate to individuals who submit a report to us, including what we’ve done as a result of their submission
To ensure legal compliance
- Comply with legal requirements
- Assist law enforcement
To process your information as described in this Privacy Policy, we rely on the following legal bases:
-
Provide our service to you: The reason we process your information for purposes 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, make it viewable to other members and recommend other
members to you and to otherwise provide our free and paid features to you and other members.
-
Legitimate interests: We process your information for purpose, based on our legitimate interest. For instance,
we analyze users’ behavior on our services to continuously improve our services. We also process information to
help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement
and enable us to defend ourselves in the event of a legal action.
-
Comply with applicable laws and regulations: We process your information for where it is necessary for us to
comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations.
For example, we retain traffic data and data about transactions in line with our accounting, tax and other
statutory data retention obligations and to be able to respond to valid access requests from law enforcement.
We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given
feature or processing.
-
Consent: From time to time, we may ask for your consent to collect specific information such as your precise
geolocation or use your information for certain specific reasons. In some cases, you may withdraw your consent
by adapting your settings (for instance in relation to the collection of our precise geolocation) or by
deleting your content (for instance where you entered information in your profile that may be considered
“special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the
address provided at the end of this Privacy Policy.
How We Share Information
Since our goal is to help you make meaningful connections, the main sharing of members’ information is, of course,
with other members. We also share some types of members’ information with service providers and partners who assist
us in operating the services.
With other members
You share information with other members when you voluntarily disclose information on the service (including your
public profile). Please be careful with your information and make sure that the content you share is stuff that
you’re comfortable being visible.
If you choose to limit the audience through use of ghost mode for all your profile and location, then it will not
be visible according to your ghost mode settings.
-
If someone submits a report involving you (such as a claim you violated our Terms and Community Guidelines, we
may communicate to the reporter actions, if any, we took as a result of their report.
-
With our service providers and partners
We use vendors to help us operate, distribute, market and improve our services, such as data hosting and
maintenance, analytics, customer care, marketing, advertising and security operations. We also share
information with vendors who distribute and assist us in advertising our services.
-
With our affiliates
We may share your information with affiliates for limited legitimate purposes as laid out below:
-
To make all SozialMe services safer and enable us to address (e.g., ban) bad actors found on one
platform also on the others
-
For them to assist us in data processing operations, as processors / service providers, upon our
instructions and on our behalf. Their assistance may include technical processing operations, such as
data hosting and maintenance, customer care, marketing and targeted advertising, analytics, finance and
accounting assistance, improving our service, securing our data and systems and fighting against spam,
abuse, fraud, infringement and other wrongdoings
-
For corporate transactions
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.
-
With law enforcement / when required by law
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.
-
To enforce legal rights
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 members, 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.
-
With your consent or at your request
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, location in de-identified form), as well
as personal information in hashed, non-human readable form, under any of the above circumstances. We may combine
this information with additional non-personal information or personal information in hashed, non-human readable
form collected from other sources.
Cross-Border Data Transfers
Sharing of information may involve cross-border data transfers to the United States of America and other
jurisdictions that may have different laws about data processing. When we transfer personal information outside of
the EEA, the United Kingdom, Switzerland or other countries which data protection laws have been deemed adequate by
the European Commission or other competent governmental standard contractual clauses which are commitments between
companies transferring personal data, binding them to protect the privacy and security of your data or other
appropriate transfer mechanism.
Your Rights and Choices
We want you to be in control of your information, so we want to remind you of the following options and tools
available to you:
-
Access / Update tools in the service. Tools and account
settings can help you access, rectify or remove information that you provided to us and that’s associated with
your account directly within the service.
-
Device permissions. Mobile platforms can have permission
systems for specific types of device data and notifications, such as phone contacts, pictures, location
services, push notifications and advertising identifiers. You can change your settings on your device to either
consent or oppose the collection or processing of the corresponding information or the display of the
corresponding notifications. Of course, if you do that, certain services may lose functionality.
-
Uninstall. You can stop all information collection by an app by
uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does
NOT close your account. To close your account, please use the corresponding delete account functionality on the
service.
-
Account closure. You can close your account by profile using
the corresponding delete account functionality directly on the service.
We also want you to be aware of your privacy rights. Depending on where you live, you may have the right to:
-
Access/know. You may have the right to request a copy of the
information we keep about you, and in certain circumstances to receive this in a portable format. You can
exercise your right to access directly within the service requesting it.
-
Delete/erase. You may request that we delete the personal
information we keep about you. You can exercise your right to delete by requesting it.
-
Correct/rectify/update. You can correct most information you
provided to us by editing your profile directly in the service. If you believe the information we hold about
you is inaccurate, you may contact us to rectify it.
-
Object/restrict. You may also have the right to object to or
request that we restrict certain processing. To do so, please do contact us.
For your protection and the protection of all of our members, we may ask you to provide proof of identity before we
can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate
you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the
privacy or other rights of someone else. If you wish to receive information relating to another member, such as a
copy of any messages you received from them through our service, the other member will have to contact us to
provide their written consent before the information is released. We may also ask them to provide proof of identity
before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict
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 and thus cannot
ensure that you are 16 years of age or older.
In certain countries, including in the European Economic Area and the United Kingdom, 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 may be that of your habitual residence,
where you work or where an alleged infringement took place.
How Long We Retain Your Information
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by
applicable law. If you decide to stop using our services, you can close your account by deleting your account and
your profile will stop being visible to other members. Note that we will close your account automatically if you
are inactive for a period of two years. After your account is closed, we will delete your personal information, as
laid out below:
-
To protect the safety and security of our members, we implement a safety retention window of three months
following account closure, or one year following an account ban. During this period, we keep your information
in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of
information during this safety retention window is based on our legitimate interest as well as that of
potential third-party victims.
-
Once the safety retention window elapses, we delete your data and only keep limited information for
specified purposes, as laid out below:
-
a) We maintain limited data to comply with legal data retention obligations: in particular, we keep
transaction data for 10 years to comply with tax and accounting legal requirements, credit card
information for the duration the user may challenge the transaction and “traffic data” / logs for one
year to comply with legal data retention obligations. We also keep records of consents members give us
for five years to evidence our compliance with applicable law.
-
b) We maintain limited information on the basis of our legitimate interest: we keep customer care
records and supporting data as well as imprecise location of download/purchase for five years to
support our customer care decisions, enforce our rights and enable us to defend ourselves in the event
of a claim, information on the existence of past accounts and subscriptions, which we delete three
years after the closure of your last account to ensure proper and accurate financial forecasting and
reporting, profile data for one year in anticipation of potential litigation, for the establishment,
exercise or defence of legal claims, and data necessary to prevent members who were banned from opening
a new account, for as long as necessary to ensure the safety and vital interests of our members.
-
c) Finally, we maintain information on the basis of our legitimate interest where there is an
outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we
receive a valid legal subpoena or request asking us to preserve data (in which case we would need to
keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of
legal proceedings).
No Minors Allowed
Our services are restricted to individuals who are 16 years of age or older. We do not permit individuals under the
age of 16 on our platform. If you suspect that a member is under the age of 16, please use the reporting mechanism
available on the service.
Privacy Policy Changes
At SozialMe we’re always looking for new and innovative ways to help you build meaningful connections and strive to
make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify
you before any material changes take effect so that you have time to review the changes.
How to Contact Us
If you have questions about this Privacy Policy, you may of course contact us. We fluctuate between Atlanta USA,
Ireland and the Philippines so best if you contact us via our email:
info@sozialme.com We welcome your feedback.