We’re Superfy Technologies Ltd. (including our corporate affiliates – “Superfy”, “we” or “us”), and our services let you chat with people that can help you, and match between your question and someone that can answer, immediately starting a chat with relevant people.
Naturally, anything that you or other Users submit, upload, post, broadcast or otherwise make available on our Services, may relate to a “personally identifiable” individual and then be considered as “Personal Data”, or not (and then it won’t be considered as Personal Data).
You are not legally required to provide us with any Personal Data, including any sensitive or “special categories” of Personal Data, nor to share these with any of our Users – so please exercise caution and common sense when sharing, uploading or otherwise using Personal Data in the context of our Services.
We use various methods to collect Personal Data: directly from you; through other sources with your permissions; and through your use of the Services.
Additionally, if you contact us (or otherwise interact with us via the Services), we typically record and process your inquiry and our correspondence, and all data you provide therein.
Data received from Facebook: If you choose to connect your Facebook to our Services, we will have access to the following data (to the extent that such data is available on Facebook and subject to your permission): your full name, profile picture, gender, date of birth, page likes, timeline posts, location and email address.
Data we collect from your use of the Services: In the course of your use of our Services, we may collect and process additional data which is necessary for rendering our Services to you, or for other purposes as described below.
This includes technical data which your device communicates to our servers, such as your IP address, device type and model, operation system version, device and hardware settings, advertising ID and crash data.
We also collect logs and chat data , as you use and interact with our Services. This means that we are recording your use of our Services, the frequency and scope of your use of the Services, your communications with other Users, access times, cookie data (as further explained in Section 7 below), and additional related metadata, such as the time, date, general location and GPS data.
Lastly, we may also gather statistical and aggregated data originating from our Users, which may be combined with additional data collected from other sources, regarding the use of the Services. This data will be anonymous and will not allow, by reasonable means, to identify – or to be attributed to – a specific person. We will use this aggregated, non-personal data for the purposes of internal research and development, and we also may share it with our business partners, affiliates or other third parties including advisors, advertisers and investors, at our discretion and for various purposes.
We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understand how our Services are used, optimize our marketing and advertising services, enable customer service and support operations, and protect and secure our Users, ourselves, and our Services.
Specifically, we store and process your data for the following purposes:
Your Sharing of Data: Our Services, specifically the features enabling you to ask a question to unknown participants, are naturally aimed for sharing. This is most significantly reflected by the fact that we relay the Services on a social network platform. However, this does not mean that you have to share all information for the use of our Services. You can always control what you share and with whom you share it by simply choosing the “anonymous” option or by contacting us. This also means that you have control over Personal Data you share such as your age, gender and location.
Our Sharing of Data: We will not share your Personal Data with third parties, except in the following instances:
Our sharing of Non-Personal Data: We may also share aggregated or non-personally identifiable data that we collect and share at our discretion as further described above under the “Data collection” section.
Access to Personal Data: Since most of your Personal Data is provided by you, mainly through your Facebook account, you have full access to your Personal Data that is processed by us. That said, you may still request a copy of the Personal Data stored with us by contacting email@example.com and we will provide it to you - subject to applicable law and to our ability to appropriately identify you as such data's subject (in accordance with our internal processes, which are designed to protect the privacy of our Users), and as long as it does not infringe third parties’ rights.
Rectification of Personal Data: You are responsible for making all necessary changes to correct any Personal Data in your account that is inaccurate, incomplete or outdated. Please keep in mind that false, incorrect, or outdated data may prevent you from registering to or using our Services and impair our ability to provide you with our Services. If you have a reason to believe we possess incorrect Personal Data relating to you, you may request the amendment of such Personal Data by contacting firstname.lastname@example.org.
Deletion of Data: You may contact us at all times at email@example.com with a request to delete your Personal Data held with us. Subject to our ability to appropriately identify you as such data's subject (in accordance with our internal processes), and as required under applicable law, we will make an effort to comply with this request and delete any Personal Data which is associated with you. However, please be aware that we use backup systems in which your data may be stored without the ability to delete it immediately upon request. Therefore, we may require an additional short period of time until we are able to fully delete all traces of your Personal Data.
Nonetheless, for legal reasons, organizational reasons or in order to prevent fraud or abuse, we may retain certain specific Personal Data relating to you. In any event, your request for deletion and any related communications may be recorded and retained for legal and record-keeping purposes.
Other User Rights: Under certain circumstances you may have the right to object to the processing of your Personal Data by us, and to export certain Personal Data to another service.
Data Location: Your Personal Data may be maintained, processed and stored by us and our authorized service providers in multiple locations, including in the United States of America, Israel and other jurisdictions, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
Data Retention: We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org
In order to protect your Personal Data held with us and our service providers, we are using industry-standard physical, procedural, and electronic security measures, as appropriate.
That said, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any service providers or other recipients as described in Section 3 above.
When you are using Our Services via the App, we might utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.
A “cookie” is a small text file that is used, for example, to collect data about activity on our Services. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by you. While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
If you wish to prevent the ongoing use of your mobile device's current advertising ID, you may change your device settings to reset such advertising ID (typically, this is available under the "Privacy" or "Ads" section in your device settings).
Our Services are not designed to attract children. We do not knowingly collect Personal Data from children and do not wish to do so. Please note that the age at which a person is no longer deemed a child for the purpose of processing their Personal Data differs across EU Member States and it is in the range of 13 to 16 . We will act in accordance with the applicable legal age (unless there is not any specific local law in which case the legal age will be deemed 16 as prescribed under the GDPR). In relation to Users from the US the legal age is 13. If we learn that we collect data relating to a person under the legal age – depending on the relevant jurisdiction as provided above - we will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at email@example.com
DPO: Superfy has appointed the privacy experts of PrivacyTeam.com as our Data Protection Officer, for monitoring and advising on Superfy's ongoing Privacy compliance efforts, and serving as a point of contact on Privacy matters for data subjects and supervisory authorities. PrivacyTeam may be reached at firstname.lastname@example.org
EU Representative: Dr. Andreas Maetzler ( https://gdpr-rep.eu/) has been designated as Superfy’s representative in the European Union and in the United Kingdom ("UK") for data protection matters. Dr. Maetzler may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to email@example.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or in the UK as applicable.
Contact: You can address any question or concern you may have with regard to this Policy, or if you have a reason to believe that your privacy or the privacy of your Personal Data has been compromised, to our privacy team by sending an email to: firstname.lastname@example.org
Last updated: 17 September 2020.