Recently updated: July 2018
Superfy Technologies Ltd. ("Superfy" or "us") is committed to your right to privacy.
THE HIGHLIGHTS :
1. What is Personal Data, and what data is collected about me by Superfy?
"Personal Data", means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.
We collect non-Personal Data regarding Users concerning their use of the App and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device identifiers, and other technical information regarding the device used to access the Services, such as model, operating system, etc.
1.1. In order to use the Services, you will be asked to create an account by providing certain Personal Data, such as your name, email address and a password of your choice (the "Account"). When connecting to the App from your Facebook account, we collect certain Personal Data from your Facebook account, in order to provide you with the App and the Services.
1.2. When you post questions and answers on the App, we collect and Process such information. Please note that the App is not intended for private or confidential content, and any content posted on the App may be reviewed by Superfy or other users.
1.3. We collect and Process User Content posted on the App or sent through the App to other users.
1.4. We also may use and collect your real time location, among others, in the form of GPS signals and other information sent by your mobile device on which the App is installed, or by identifying the wireless networks available for your device at certain times, in order to provide you with responses of Users relevant to your location. You may program your device to block our access to your location data but be aware that such blocking may prevent us from providing you some of the Services.
1.5. We do not knowingly collect or Process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the App or collected by us, please inform us immediately.
1.6. In the event you post any Personal Data included in Special Categories of Personal Data, such as information on health or medical state, sexual life or orientation, religious belief, etc., you explicitly acknowledge and agree that such data may be Processed by us or other users on the App.
1.7. Use discretion when posting content on the App. The App connects you to others users, without notifying you in advance to which user your question or answer may reach. You should be aware that questions you post on the App may reach anyone, including people you may know or who know you, and you should not post any questions or answers you wish to keep confidential or private.
Please note, that the App may contain links to other websites maintained by third parties, which may not be governed by this Privacy Notice. This Privacy Notice does not be applied to the practices of entities which are not controlled by Superfy.
2. Are Questions, Answers and Other Content on the App Private?
NO. ANY CONTENT YOU POST ON THE APP, SUCH AS QUESTIONS, ANSWERS, ETC., MAY BE VIEWED BY US OR OTHER USERS, AND IS NON CONFIDENTIAL IN NATURE. DO NOT POST PRIVATE INFORMATION OR PERSONAL DATA ON THE APP.
3. What will Superfy do with my Personal Data?
3.1. Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our App and Services, including among others, in order to measure and understand the level of engagement to our services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services and features.
3.2. Personal Data. Personal Data is used only for the following limited purposes:
3.2.1. To provide you with the Services. For example, we analyze Personal Data regarding you as publicly available on your Facebook account, and as you have agreed to provide to us, even if not publicly available, in order to enable us to make the most suitable match between you and another user on the App.
For example, if a certain user has expertise in the field of cooking, as demonstrated by his/her Facebook account information (such as posts, likes, etc.), the App may forward to such user a question a different user posted through the App about cooking.
3.2.2. To communicate with you regarding customer service issues, or to provide updates with respect to material changes to this Privacy Notice or our Terms and Conditions.
3.2.3. To respond to questions or comments and to help resolve any problems.
3.2.4. For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, and as permitted under applicable law.
3.2.5. To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.
3.2.6. To improve the Services, and to develop new features, products and services.
3.2.7. To improve your experience on the App and customize our Services to your interests.
5. What can I do to control my Personal Data?
5.1. Reviewing and amending your Personal Data. You may review the information included in your account on the App. You may also send us a request in connection with your Personal Data to: email@example.com. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the App.
5.2. Right of erasure and restriction. You may also be entitled to request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
5.3. Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
5.4. Retention of Data. We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.
6. Will Superfy Share my Personal Data?
6.1. Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.
6.2. We share Personal Data only under the following limited circumstances:
6.2.1. With other users on the App, in order to provide you and our users with the App and the Services.
For example, we may share your profile information (such as your name and profile picture), to another user when creating a match between you in the context of the App.
6.2.2. With trusted third parties who assist us in operating the Services, conducting our business, and for personalizing your experience of the App, including by way of targeted advertising on the App.
6.2.3. To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
7. What is the lawful basis under which Superfy processes Personal Data?
7.1. Certain processing activities conducted by us are based on the necessity of such activities for the performance of the understandings between us and our Users. For example, we need to disclose certain Personal Data regarding you to other users in order to provide you with our Services.
7.2. Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.
7.3. There may be certain processing activities based on your consent to this Privacy Notice. In connection with such activities, you may rescind your consent, by sending us an email to: firstname.lastname@example.org . Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.
8. Will Superfy transfer my Personal Data internationally?
Our databases are currently located in the U.S. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.
Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users' rights.
9. Will I receive SPAM from Superfy?
We currently do not send Users any commercial or promotional information via direct mailing such as emails or SMS messaging. We will not send any User such promotional mailing without obtaining the User's explicit prior consent.
10. Persons under 16
Our App is a general audience App, which is not directed to persons under 16 years old, or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction (for example, 13 in the U.S.) . If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.
11. Applicable Laws
The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.
12. Questions or concerns regarding privacy
If you have any questions or concerns regarding privacy issues, please send us a detailed message to email@example.com and we will make every effort to resolve your concerns without delay.
Superfy may, at any time and from time to time, modify this Privacy Notice. Modifications to this Privacy Notice will be posted on the App, and shall be effective as of the date in which they are posted on the App.
You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.