1. Information we collect about you
In General. We may collect Personal Information, including Sensitive Data, and other information. “Personal Information” means individually identifiable information that would allow us to determine the actual identity of, and contact, a specific living person. Sensitive Data includes information, comments or content(e.g. photographs, video, profile, lifestyle) that you optionally provide that may reveal your ethnic origin, nationality, religion and/or sexual orientation. By providing Sensitive Data to us, you consent to the collection, use and disclosure of Sensitive Data as permitted by applicable privacy laws. We may also collect your geolocation information with your consent. We may collect this information through a website, mobile application, or other online services. By using the Service, you are authorizing us to gather, parse and retain data related to the provision of the Service. When you provide personal information through our Service, the information may be sent to servers located in the United Kingdomand countries around the world.
- Information you provide. In order to register as a user with Suppa, you will be asked to sign in using your Facebook login. If you do so, you authorize us to access certain Facebook account information, such as your public Facebook profile (consistent with your privacy settings in Facebook), your email address, interests, likes, gender, birthday, education history, relationship interests, current city, photos, personal description, friend list, and information about and photos of your Facebook friends who might be common Facebook friends with other Suppa users. You will also be asked to allow Suppa to collect your location information from your device when you download or use the Service. In addition, we may collect and store any personal information you provide while using our Service or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, financial information. You may also provide us photos,a personal description and information about your gender and preferences for recommendations, such as search distance, age range and gender. If you chat with other Suppa users, youprovide us the content of your chats, and if you contact us with a customer service or other inquiry, you provide us with the content of that communication.
- Information from other sources. We may obtain both personal and non-personal information about you from other third parties.
- Use of technologies to collect information.We use various technologies to collect information from your device and about your activities on our Service.
- Information collected automatically. We automatically collect information from your browser or device when you visitour Service. This information could include your IP address, device ID and type, your browser type and language, the operating system used by your device, access times, your mobile device’s geographic location while our application is actively running, and the referring website address.
- Cookies and use of cookie and similar data. When you visit our Service, we may assign your device one or more cookies or other technologies that facilitate personalization to facilitate access to our Service and to personalize your experience. Through the use of a cookie, we also may automatically collect information about your activity on our Service, such as the pages you visit, the time and date of yourvisits and the links you click. If we advertise, we (or third parties) may use certain data collected on our Service to showyou Suppa advertisements on other sites or applications.
- Pixel tags. We embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. These tiny, invisible graphics are used to access cookies and track user activities (such as how many times a page is viewed). We use pixel tags to measure the popularity of our features and services. Ad companies also use pixel tags to measure the number of ads displayed and their performance (such as how many people clicked on an ad).
- Mobile device IDs. If you’re using our app, we use mobile device IDs (the unique identifier assigned to a device by the manufacturer), or Advertising IDs (for iOS 6 and later), insteadof cookies, to recognize you. We do this to store your preferences and track your use of our app. Unlike cookies, device IDs cannot be deleted, but Advertising IDs can be resetin “Settings” on your iPhone. Ad companies also use device IDs or Advertising IDs to track your use of the app, track the number of ads displayed, measure ad performance and display ads that are more relevant to you. Analytics companies use device IDs to track information about app usage.
- Information collected by third-parties for advertising purposes. We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements on our Service and elsewhere. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements. We do not provide any non-masked or non-obscured personal information to third parties.
2. How we use the information we collect
- deliver and improve our products and services, and manage our business;manage your account and provide you with customer support;
- perform research and analysis about your use of, or interest in, our or others’ products, services, or content;
- communicate with you by email, postal mail, telephone and/ormobile devices about products or services that may be of interest to you either from us or other third parties;
- develop, display, and track content and advertising tailored to your interests on our Service and other sites, including providing our advertisements to you when you visit other sites;
- website or mobile application analytics;
- verify your eligibility and deliver prizes in connection with contests and sweepstakes;
- andperform functions or services as otherwise described to you atthe time of collection.
Job applicants. If your Personal Information is submitted when applying for a position with our company, the information will be used solely in connection with considering and acting upon your application. We may retain your Personal Information, but only forthe purpose of considering your application for current or future available positions. This information, which may include your name and contact information, prior education and experience, and other information you provide to us, may be shared with third-party service providers retained by us to collect, maintain and analyze candidate submissions for job postings.
In all circumstances, we may perform these functions directly or use a third party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us. Also, if you access our Service from a third party social platform, such as Facebook, we may share non-personal information with that platform to the extent permitted by your agreement with it and its privacy settings.
3. With whom we share your information
Information Shared with Other Users. When you register as a user of Suppa, your Suppa profile will be viewable by other users of the Service. Other users (and in the case of any sharing features available on Suppa, the individuals or apps with whom a Suppa user may choose to share you with) will be able to view information you have provided to us directly or through Facebook or Instagram, such as your Facebook photos, any additional photos you upload, your first name, your age, approximate number of miles away, your personal description, and information you have in common with the person viewing your profile, such ascommon Facebook friends and likes. If you swipe right or use voting buttons to say “yes” to a person, you will be able to chat with that person if they swipe right or use voting buttons to say “yes” to you, e.g., when you have a “match.” If you chat with your match, of course your match will see the content of your chat.
- Service providers. We may share information, including personal and financial information, with third parties that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, member screenings, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through our Service. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
- Other Situations. We may disclose your information, including personal information:
- In response to a subpoena or similar investigative demand,a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Aggregated and/or non-personal information. We may use and share non-personal information we collect under any of the above circumstances. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis, advertising, marketing, or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form. We may also share your geolocation information in de-identified form with third parties for the above purposes. To opt out of the sharing of your geolocation information, please discontinue use of the Suppa application.
4. Do Not Track disclosure
Do Not Track (“DNT”) is a privacy preference that users can set intheir web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide the opt-out links above. However, we do not recognize or respond to any DNT signals, as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
5. Third-party websites
6. How you can access and correct your information
If you have a Suppa account, you have the ability to review and update your personal information within the Service by opening your account and going to settings. Applicable privacy laws may allow you the right to access and/or request the correction of errors or omissions in your personal information that is in our custody or under our control. Our Privacy Officer will assist you with the access request. This includes:
- Identification of personal information under our custody or control; and
- Information about how personal information under our control may be or has been used by us.
We will respond to requests within the time allowed by all applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization to which it was disclosed.
In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold. For security purposes, not all personal information is accessible and amendable by the Privacy Officer. If access or corrections cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
7. Data retention
8.Your choices about collection and use of your information
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Service because such information may be required in order for you to register as user; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions.
Our Service may also deliver notifications to your phone or mobile device. You can disable these notifications by going into “App Settings” on the app or by changing the settings on your mobile device.
You can also control information collected by cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions.
9. How we protect your personal information
We take security measures to help safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. Therefore, although we takesteps to secure your information, we do not promise, and you should not expect, that your personal information, chats, or other communications will always remain secure. Users should also takecare with how they handle and disclose their personal informationand should avoid sending personal information through insecure email.
You agree that we may communicate with you electronically regarding security, privacy, and administrative issues, such as security breaches. We may post a notice on our Service if a security breach occurs. We may also send an email to you at the email address you have provided to us. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at [email protected]
10. Information you provide about yourself while using our Service
11. Children's privacy
Although our Service is a general audience Service, we restrict the use of our service to individuals age 18 and above. We do not knowingly collect, maintain, or use personal information from children under the age of 18.
12. Onward transfer and consent to international processing
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by Suppa from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing inaccordance with this Policy
13. No Rights of Third Parties
15. How to contact us