Privacy Policy

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to all websites, apps, events and other services operated by Simposi. For simplicity, we refer to all of these as our "services" in this Privacy Policy. To make it extra clear, we've added links to this Privacy Policy on all applicable services. Where a service requires its own unique privacy policy, then that policy -- not this Privacy Policy -- will apply.

INFORMATION COLLECTION, USAGE & SHARING

It goes without saying, that in order to help match you with other people we’re going to need a little bit of information about you, such as basic personal details and the types of people you'd like to meet. Information is also collected as you use our services, for example access logs, personality profiles, user ratings and the like.

When you create an account, you provide us with your login credentials, as well as some basic details necessary for the service to work, such as what age and gender you identify as well as what you do for work. After you complete the basic profile you have the option to share additional information with us, such as details on your personality, lifestyle, interests and other details about you that aid in the matching process. To add certain content, like pictures to your profile or social activities, you may need to allow us to access your camera or photo album. For the most part we try to collect the most generic information about you and rarely collect information that may be considered "special" or "sensitive". However, some of the information we collect may still be considered "special" or "sensitive" in certain jurisdictions. By choosing to provide this information, you consent to our processing of that information.

We may also collect information as you interact with our company or services and by choosing to engage with our company or services you consent to our processing of your data. This includes, but is not limited to the following:

- We collect information such as your debit or credit card number or other financial information when you subscribe to a paid service or make a purchase directly from us. Information may also be collected by our payment providers.
- We collect information, insights, responses and testimonials when you participate in surveys or focus groups.
- We collect information when you choose to participate in our promotions, events or contests.
- We collect information if you contact our customer care team. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
- We may collect the information about others that you give us 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 also collect information when we process your chats with other users as well as the content you publish, as part of the operation of the services.
- 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).
- We may collect information from and about the device(s) you use to access our services, including: hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google's AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device' settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address), wireless and mobile network connection, service provider, signal strength, and information from device sensors such as accelerometers, gyroscopes and compasses.
- With your permission, we collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you're using, including GPS, Bluetooth or WiFi connections. If the permission you gave us expressly permits such collection, we may collect your geolocation in the background even when you aren't using the services. If you decline permission for us to collect your geolocation, we will not collect it.

WHAT WE COLLECT FROM OTHERS ABOUT YOU

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 social media login (such as Facebook Login) to create and log into your Simposi 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.
- We may receive info about you from our partners, for instance when Simposi accounts can be created through a partner's websites (in which case they pass along registration information to us) or where Simposi ads are published on a partner's websites and platforms (in which case they may pass along details on a campaign's success).

COOKIES AND SIMILAR DATA TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a "Do Not Track" ("DNT") feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Simposi, do not currently respond to DNT signals.

HOW WE USE YOUR INFORMATION

We try to collect as little information as possible, however the main reason we collect your information is to deliver and improve our services to you. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you.

Account creation & management

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

Connecting you with others

Analyze your profile and that of other users to recommend meaningful connections
Show users' profiles to one another

Improve services and develop new ones

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, and conduct research and analysis of users' behavior 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' behavior)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

Maintain a safe community

Address ongoing or alleged misbehavior 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

Maintain legal compliance

Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights, for example our Terms & Conditions
We may use your information where we have legitimate interests to do so. For instance, we analyze users' behavior 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.
From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

HOW WE SHARE INFORMATION

Our goal is to help you meet new people, which means we primarily share your information with other users. We also share some users' information with service providers and partners who assist us in operating the services and, in some cases, legal authorities.

You share information with other users when you voluntarily disclose information on our service (including your profile). 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.

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 follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, 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 behavioral data, geolocation in deidentified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.

CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area ("EEA"), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

YOUR RIGHTS

In order to help you maintain control of your information we have provided you with the following tools:

- Ability to Edit Profile. Tools and account settings that help you to access, rectify or delete information that you provided to us and that's associated with your account directly within the service.
- 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.
- Reviewing your information. You can request a copy of your personal information by putting in such a request by emailing us at support@simposi.com.
- Updating or Deleting your information. You can delete your account by using the corresponding functionality directly on the service.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, and are unable to do so yourself, please contact us by emailing support@simposi.com.
- Written Consent. Our Privacy officer will contact you to request your written consent before disclosing your information, when it has been requested by another user pertaining to interactions you may have had on the application.
- Proof of Identity. 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 and we may reject requests for certain reasons, including if the request is unlawful or if it infringes on trade secrets or intellectual property or the privacy of another user.

Please note, we may not be able to accommodate certain requests 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 you do not complete certain profile features such as gender identification, age identification, etc. It is recommended that you uninstall the application in the event you do not wish to identify with any of the provided profile options for creating a profile. All information collection will cease by uninstalling the application from your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

RESIDENTS OF CALIFORNIA

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized 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 organizational 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 here.

HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5 and as permitted by applicable law). In practice, we delete or anonymize your information upon deletion of your account unless:

- we must keep it to comply with applicable law;
- we must keep it to evidence our compliance with applicable law;
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- 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 behavior 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

CHILDREN'S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

CHANGES TO THIS POLICY

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.

HOW TO CONTACT US

If you have questions about this Privacy Policy, here's how you can reach us:

Online: support@simposi.com

By post:

WHO WE ARE