Privacy Policy

Welcome to Superfy’s Privacy Policy!

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.

This Privacy Policy ("Policy") describes our practices regarding personal data of our website visitors and mobile application users (“User(s)” or “you”), as they download, access and use our mobile application (“App”), or otherwise interact with any of our websites, online ads, properties or media (collectively - the “Services”).

Specifically, this Privacy Policy describes our practices regarding –

  1. Data Collection
  2. Data Uses
  3. Data Sharing
  4. Data Subject Rights
  5. Data Location & Retention
  6. Data Security
  7. Cookie and Tracking Technologies
  8. Children’s Privacy
  9. Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to the practices described in this Policy, please avoid and discontinue using our Services.

  1. Data Collection

  2. 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”.

    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 typically collect Personal data directly from you; through other sources with your permissions; and through your use of the Services:

    Data you provide us: When you register to the App or otherwise interact with the Services, you may provide us with Personal data about you. This includes:

    Profile Information: When you sign up and create your individual profile (“Profile”), you may provide us with certain data such as your name, birthdate, location, gender, bio, photos that you have uploaded to your personal gallery (“Gallery”), and any other information you choose to provide us. Please note that you can change the privacy settings in your Profile at any time if you wish to hide your real name, location, age and Gallery from other users, however we will still process such information in accordance with this Privacy Policy. In the course of your use of our Services, you may also generate additional data related to your Profile, such as the number of “Super Coins” you own or use for in-App stickers or other prizes offered on or off the App to customize and distinguish your Profile.

    Content Data: When you submit or answer a question, we may process the content of the messages, images and pictures, video or audio, or any other information shared by you or other Users through the App. We monitor these, for example, for moderation purposes. For more details on the purposes we process your data for, see below.

    Interactions and communications: If you contact us (e.g., for user experience, support or to report a User), we typically record and process your inquiry and our correspondence, and all data you provide therein.

    Data received from Facebook or Apple: If you choose to connect your Facebook or Apple to our Services, we will have access to the following data (to the extent that such data is available on Facebook or Apple and subject to your permission): your full name, profile picture, gender, date of birth, page likes, timeline posts, location and email address. We may not post or send friend requests on your behalf on Facebook.

    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.

  3. Data Uses

  4. We use Personal Data as necessary for the performance of our Services (“Performance of Contract”); to comply with applicable law (“Legal Obligations”); 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 (“Legitimate Interests”).

    If you reside or are using the Services in a territory governed by privacy laws which determine that "consent" is the most appropriate legal basis for the processing of Personal Data (either in general, based on the types of Personal Data you expect or elect to process or have processed by us or via the Services, or due to the nature of such processing) (“Consent”), your acceptance of our Terms of Use and of this Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at privacy@superfy.co

    Specifically, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

    1. To facilitate, operate, and provide our Services (Performance of Contract);
    2. To authenticate and verify the identity and eligibility of our Users (Legitimate Interests);
    3. To provide our Users with assistance and support (Performance of Contract);
    4. To manage advertisements more effectively, including contextual, behavioral, and interests-based advertising for our own products and services, based on Users’ activities, preferences or other data available to us or to our business partners, including for retargeting purposes (Legitimate Interests);
    5. To further develop, customize, and improve the Services, based on common or personal preferences, experiences, and difficulties (Legitimate Interests);
    6. To contact our Users with general or personalized service-related messages and promotional messages; and to facilitate, sponsor, and offer certain events and promotions (Consent);
    7. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity (Legitimate Interests);
    8. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use at our discretion, including to provide and improve our respective Services (Legitimate Interests);
    9. To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation); and
    10. For any other lawful purpose in connection with provisioning our Service and Sites (Legal Obligation).
  5. Data Sharing

  6. 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 “Privacy mode” or by contacting us. This also means that you have control over Personal Data you share such as your age, gender, location and Gallery.

    Our Sharing of Data: We will not share your Personal Data with third parties, except in the following instances:

    1. When we engage third parties to process Personal Data on our behalf. Such processing activities will be subject to our instructions and in compliance with this Policy. These include data hosting services, data analytics services, marketing and advertising services, data and cyber security services, email distribution and monitoring services, and our business, legal, privacy and financial advisors. These parties may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
    2. In response to a legal request or requirement, (i) if we believe that we are required to do so under applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud and other illegal activities; enforce our Terms of Use, including in order to investigate potential breaches thereof; protect our rights, property or safety, or those of our Users or members of the public from harm, as required or permitted by applicable law; and prevent death or imminent bodily harm.
    3. With our affiliates. This relates to entities that are legally part of the same group of companies that we are part of, or that become part of that group.
    4. In case of a change of control or ownership. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, fundraising or similar transaction or proceeding resulting in a change of control or ownership, we may share Personal Data with the parties involved in such event. If we believe that such an event might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via prominent notice on our Services.
    5. With other Users. We may share the Personal Data of Users with the Users they interact with (for example, if you submit a question or a response, your will be visible to the Users you are matched with). Superfy is not responsible for and does not control any further disclosure, use or monitoring of such data by or on behalf of such User you engage with – so please exercise caution and common sense when sharing, uploading or otherwise using Personal Data when conversing with other Users.
      Where no suitable User is found, the App may provide you with an answer from a bot using artificial intelligence technology ("Bot"). It will be clear that this answer is not provided by another User.
    6. When we have received your specific permission. This includes sharing data as described in this Policy or otherwise with other services (like Facebook) when you have chosen to link these services to your Profile or publish your activity on our Services to them. Please note that we do not actively share your data with Facebook nor do we post anything on your behalf or disclose your data.

    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 in Section 1 above.

  7. Data Subject Rights

  8. You have the following rights regarding your personal data:

    Access your Personal Data: Since most of your Personal Data is provided by you, 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 privacy@superfy.co 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.

    Rectify your 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 privacy@superfy.co.

    Request the deletion of your Personal Data: You may contact us at all times at privacy@superfy.co 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 Rights: Under certain circumstances you may have the right to restrict or object to the processing of your Personal Data by us (including the right to direct us not to sell your Personal Data to third parties now or in the future), to obtain a copy or port certain Personal Data to another service, the right to opt-out of automated decision-making, or the right to equal Services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EEA or the UK, as applicable.

    In accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), if a User is a minor under the age of 13, a User’s parent or legal guardian may (upon request), access the child’s Personal Information in order to (i) review it; (ii) request that it be deleted; and/or (iii) prevent further use or collection.

    To exercise these rights and receive further information, please contact us by email at privacy@superfy.co.

  9. Data Location & Retention

  10. 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.

    Superfy is headquartered in Israel, a jurisdiction which is considered by the European Commission, the UK Information Commissioner’s Office, and the Swiss Federal Data Protection and Information Commissioner, to be offering an adequate level of protection for personal data of individuals residing in EU Member States, the UK and Switzerland, respectively. We transfer data from the EEA, the UK and Switzerland to Israel on this basis.

    While privacy laws may vary between jurisdictions, Superfy and its affiliates and service providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. For data transfers from the EEA, UK, or Switzerland to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers entered into Standard Contractual Clauses (“SCC”), as approved by the European Commission and UK ICO. You are entitled to request a copy of these SCC by contacting us as indicated in Section 9 below.

    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 and at our reasonable discretion. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements.

    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 privacy@superfy.co.

  11. Data Security

  12. 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.

    However, 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.

  13. Cookies and Tracking Technologies

  14. When you are using Our Services via the App or visiting our website, 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. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy.

    Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.

    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).

  15. Children’s Privacy

  16. 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 – without such consent, we will make all efforts to promptly delete any Personal Data stored with us about that child. If you believe that we might have any such data, please contact us by email at privacy@superfy.co.

  17. Additional Notices and contact details

  18. Updates to this Policy: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

    External Links: Our Services may contain links to third party sites or other apps or services that are not owned or operated by Superfy (for example, links submitted by other Users, or through Superfy’s social media posts). This Privacy Policy only applies to Superfy’s Services and does not apply to any third-party sites, apps, platforms or any other service. We are not responsible for the privacy practices or terms of such other third parties even if our name and logo appear on the screen. We recommend that you review the privacy policies of such third parties (including Facebook) before you use any apps or services they offer.

    California Requirements: This Privacy Policy describes the categories of personal information we may collect and the sources of such information (in Section ‎1 above), and our retention (Section 5) and deletion (Section 4) practices. We also included information about how we may process your information, which includes “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intentions and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Sections 3 and 5 above, if those third parties are authorized Services Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the Services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 3 above. If you have any questions or would like to exercise your rights under the CCPA, you can contact dpo@superfy.co.

    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 dpo@superfy.co.

    EU and UK Representative: Dr. Andreas Maetzler (https://gdpr-rep.euprivacy@superfy.co. EU inquiries may be sent to: Prighter (Attn: Superfy), Schellinggasse 3/10, Vienna 1010, Austria. UK inquiries may be sent to: Prighter (Attn: Superfy), Kemp House 160 City Road, EC1V 2NX, London, United Kingdom.

Last Updated: Oct, 2022