We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.
It goes without saying, we can’t help you develop meaningful connections without some information about you. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more details below.
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 login credentials (email), as well as some basic details necessary for the service to work, such as your gender and year of birth. • When you complete your profile, you can also upload a profile picture. To add a profile picture, you may allow us to access your camera or photo album.
• When you subscribe to interests, we require access to this information to be able to match you with other users. We also require this information for other features like Eavesdropping.
• When you choose to match with other users by distance, you allow us to collect location data that will be provided by your device's GPS services.
• When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
• When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
• If you contact our customer support team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
• If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
• Of course, we also process your chats with other users as well, as part of the operation of the services. However, we do not store any chats on our servers (only temporarily until it is sent, and then it will be deleted).
• Chat messages in Match Chats (chats when we match you with other users by interests) are free to be read by other users through the Eavesdropping feature. If you need to have a private conversation with a user, you will need to add that user as a friend.
• Chat messages in Friend Chats (chats between your friends) are strictly private between the two of you and no users outside of the two of you or third party will have access to those chats.
In addition to the information you provide us directly, we receive information about you from others, including:
Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
You may be able to use your third party logins (such as Facebook or Google Login) to create and log into your SmollTalk account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.
When you use our services, we collect information 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:
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).• Other information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
• Create and manage your account
• Provide you with customer support and respond to your requests
• Complete your transactions
• Communicate with you about our services, including order management and billing
• We will use the Interests that you subscribed in the app to help you match with other users who have subscribed to similar interests.
• Show users’ profiles to one another after they become friends.
• Register you and display your profile on new SmollTalk features and apps
• Administer your account on these new features and apps
• Administer sweepstakes, contests, discounts or other offers
• Develop, display and track content and advertising tailored to your interests on our services and other sites
• Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
• Administer focus groups and surveys
• Conduct research and analysis of users’ behaviour to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour)
• Address ongoing or alleged misbehaviour on and off-platform
• Perform data analysis to better understand and design countermeasures against these activities
• Retain data related to fraudulent activities to prevent against recurrences
• Comply with legal requirements
• Assist law enforcement
• Enforce or exercise our rights, for example our Terms and Conditions
To process your information as described above, we rely on the following legal bases:
• Provide our service to you: Most of the time, the reason we process your information 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 the interests and other profile information such as age, gender and/or location to better match you with other users.
• Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyse users’ behaviour on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users.
When you become friends with other users on SmollTalk, you share profile information with other users and/or the interests that you are subscribed to (you can opt to not show this information). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.
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.
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 users, 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.
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 behavioural data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may share your information to third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyse and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.
We want you to be in control of your information, so we have provided you with the following tools:
• Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
• Deletion. You can delete your account by using the corresponding functionality directly on the service.
We want you to be aware of your privacy rights. Here are a few key points to remember:
• Reviewing your information.
Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by contacting us at firstname.lastname@example.org.
• Updating your information.
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at email@example.com.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user.
Also, we may not be able to accommodate certain requests to object to 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 year of birth and gender.
• Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device.
We work hard to protect you from unauthorised access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organisational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately by emailing us at firstname.lastname@example.org.
When you choose to delete your account, we immediately delete your information from our systems (profile, friends, interests, etc), unless:
1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
Because we’re always looking for new and innovative ways to help you build meaningful connections, 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.