Our Dedication to Your Privacy

At SpotaFriend, safeguarding your privacy is of utmost importance to us. It lies at the

heart of how we create and develop the services and products you cherish, so that you

can have complete confidence in them while focusing on building valuable connections.

We deeply value the trust you place in us when you share your information, and we take

this responsibility seriously.

We never compromise on your privacy. When crafting our products and services, we

prioritize your privacy in every aspect. We consult experts from diverse fields, including

legal, security, engineering, and product design, to ensure that every decision made

respects and protects your privacy.

Transparency is key to how we handle your data. We understand the common issues of

insufficient information and convoluted language in privacy policies, as we also use

similar online services. Therefore, we take the opposite approach: our Privacy Policy and

related documents are written in plain language. We genuinely want you to read and

comprehend our policies and understand how we prioritize your privacy.

We make diligent efforts to ensure the security of your information. Our dedicated

teams work tirelessly to keep your data safe and secure. We consistently update our

security practices and invest in enhancing the safety of your information.

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Welcome to the Privacy Policy of SpotaFriend. We appreciate your time in reviewing it,

and we value the trust you place in us. Our aim is to always maintain that trust by

ensuring you have a clear understanding of the information we collect, why we collect it,

how we use it, and the choices you have regarding your information. In order to keep

this Policy accessible, we have minimized the use of legal and technical jargon.

EFFECTIVE DATE: May 30, 2023

Applicability of this Privacy Policy This Privacy Policy applies to all the services provided

by SpotaFriend, including websites, apps, events, and other related services. To make it

even clearer, we have included links to this Privacy Policy on all applicable services.

Information We Collect It is essential for us to gather certain information about you in

order to assist you in establishing meaningful connections. This includes basic profile

details and the preferences you have for the type of people you wish to meet.

Additionally, we collect information that is generated as you use our services, such as

access logs. We may also obtain information from third parties, such as when you access

our services through a social media account. If you require further information, we

provide more details below.

1. Information You Provide to Us:

When using our services, you have the option to provide us with certain information.

This may include:

• Account Creation: When you create an account, you provide us with at least your

for the service to function, such as your gender and date of birth.

• Profile Completion: You can choose to share additional information with us by

completing your profile. This may include details about your personality, lifestyle,

interests, and other relevant information. You may also upload content such as photos

and videos. In order to add certain content, like pictures or videos, you may grant us

access to your camera or photo album. By providing this information, you consent to

our processing of it.

• Participation in Promotions: If you choose to participate in our promotions,

events, or contests, we collect the information you provide during the registration or

entry process.

• Customer Care Interactions: When you contact our customer care team, we

collect the information you provide during the interaction. In some cases, these

interactions may be monitored or recorded for training purposes and to ensure high-

quality service.

• Processing Information of Others: If you request us to communicate with or

process information of other individuals (e.g., sending an email on your behalf to one of

your friends), we collect the information about those individuals that you provide to us

in order to fulfill your request.

• Chats and Published Content: We process the chats you have with other users

and the content you publish as part of our service operations.

• GPS position is used in our app for various features, including friend matching

and other relevant functionalities. By collecting your precise geolocation information,

such as latitude and longitude, we can offer you personalized recommendations and

help you connect with other users who are nearby or share similar interests.

• Contact List Information: In certain agreed-upon promotions aimed at sharing

our brand or app, we collect your contact list information.

2. Information we receive from others:

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.

• Social Media You may be able to use your social media login (such as Facebook

remember yet another username and password and allows you to share some

information from your social media account with us.

Other Partners We may receive info about you from our partners, for instance where

SpotaFriend ads are published on a partner’s websites and platforms (in which case they

may pass along details on a campaign’s success).

3. Information Collected When You Use Our Services:

When you utilize our services, we gather information regarding the features you've used,

how you've utilized them, and the devices through which you access our services. Please

find more details below:

• Usage Information: We collect information about your activity on our services,

including how you use them. This may include the date and time of your logins, the

features you've utilized, your searches, clicks, and the pages shown to you. Additionally,

we collect information on your interactions with other users, such as the users you

connect and engage with, the timing and date of your exchanges, and the number of

messages you send and receive.

• Device Information: We collect information from and about the device(s) you use

to access our services. This includes details such as your IP address, device ID, device

type, specific app settings and characteristics, app crashes, advertising IDs (e.g., Google's

AAID and Apple's IDFA), browser type, version, and language, operating system, time

zones, and identifiers associated with cookies or other technologies that uniquely

identify your device or browser (e.g., IMEI/UDID and MAC address). We also gather

information about your wireless and mobile network connection, such as your service

provider and signal strength. Furthermore, we may collect data from device sensors like

accelerometers, gyroscopes, and compasses.

• Other Information with Your Consent: With your permission, we can collect

precise geolocation information (latitude and longitude) using various means,

depending on the service and device you are using. This can be achieved through GPS,

Bluetooth, or Wi-Fi connections. Please note that geolocation collection may occur in

the background even when you are not actively using the services, as long as the

permission you granted explicitly permits such collection. If you decline permission for

us to collect your geolocation, we will not gather this information. Additionally, if you

provide consent, we may collect your photos and videos, such as when you want to

publish a photo, video, or stream on our services.

4. Cookies and Similar Data Collection Technologies:

We utilize cookies and similar technologies, such as web beacons and pixels, to

recognize you and/or your device(s). These technologies serve various purposes,

including authentication, remembering your preferences and settings, analyzing site

traffic and trends, delivering and measuring the effectiveness of advertising campaigns,

and enabling the use of social features. For more detailed information on why we use

cookies and how you can have more control over their usage, please refer to our Cookie

Policy. You can manage their use through your browser settings and other available

tools.

It's worth noting that certain web browsers, such as Safari, Internet Explorer, Firefox, and

Chrome, offer a "Do Not Track" (DNT) feature. When enabled, the DNT feature informs

websites that the user does not wish to be tracked in terms of their online activity.

However, the implementation of DNT signals is not yet consistent across all browsers,

and not all browsers include this feature. Consequently, many businesses, including

SpotaFriend, currently do not respond to DNT signals.

5. How We Use Your Information:

We utilize your information for various purposes to deliver and enhance our services.

Additionally, we use your information to ensure your safety and provide you with

relevant advertising. Here is a detailed explanation of how we use your information,

including practical examples:

To administer your account and provide our services to you:

• We create and manage your account, allowing you to access our services.

• We provide customer support and address any inquiries or requests you may

have.

• We facilitate and complete transactions you initiate through our services.

• We communicate with you regarding our services, including order management

and billing information.

To help you connect with other users:

• We analyze your profile, activity on the service, and preferences to recommend

meaningful connections for you. We may also recommend you to other users based on

their preferences. For further details on our profiling and automated decision-making,

please refer to our FAQ.

• We display users' profiles to one another, allowing you to explore potential

connections.

6. To ensure a consistent experience across your devices:

• We link the various devices you use, allowing you to enjoy a seamless experience

of our services across all of them. This may involve linking devices and browser data,

such as when you log into your account on different devices. We may use partial or full

IP addresses, browser versions, and similar data about your devices to help identify and

link them.

To provide new SpotaFriend services to you:

• We register you and display your profile on new SpotaFriend features and apps,

expanding your opportunities to connect with others.

• We administer your account on these new features and apps, ensuring a smooth

user experience.

To serve you relevant offers and ads:

• We administer sweepstakes, contests, discounts, or other offers, enhancing your

engagement with our services.

• We develop, display, and track content and advertising tailored to your interests

on our services and other websites.

• We communicate with you via email, phone, social media, or mobile device about

products or services that we believe may interest you.

To improve our services and develop new ones:

• We administer focus groups and surveys to gain insights into user preferences

and feedback.

• We conduct research and analysis of users' behavior to improve our services and

content. Based on user behavior, we may decide to modify features or even make

substantial changes to improve the user experience.

• We develop new features and services based on user requests and feedback.

To prevent, detect, and fight fraud or unauthorized activities:

• We address ongoing or alleged misbehavior both on and off our platform,

ensuring a safe and trusted environment.

• We perform data analysis to better understand and develop countermeasures

against fraudulent or unauthorized activities.

• We retain data related to fraudulent activities to prevent future occurrences and

maintain security.

7. To ensure legal compliance:

• We comply with legal requirements imposed by applicable laws and regulations.

• We assist law enforcement agencies in their lawful investigations when required.

• We enforce and exercise our rights, such as those outlined in our Terms of

Service.

To process your information as described above, we rely on the following legal bases:

• Providing our service to you: In most cases, we process your information to fulfill

the contract you have with us. For example, as you use our service to establish

meaningful connections, we utilize your information to maintain your account, display

your profile to other users, and suggest potential matches.

• Legitimate interests: We may process your information based on our legitimate

interests. For instance, we analyze user behavior on our services to enhance our

offerings, provide personalized offers that we believe may be of interest to you, and

process information for administrative and fraud detection purposes, as well as for other

legal reasons.

• Consent: Occasionally, we may seek your consent to use your information for

specific purposes. You have the right to withdraw your consent at any time by

contacting us using the contact details provided at the end of this Privacy Policy.

Please note that we adhere to the relevant legal bases when processing your

information and prioritize the protection of your privacy and rights.

8. How We Share Your Information:

Our primary purpose is to facilitate meaningful connections, and as a result, we share

users' information primarily with other users. We also share certain users' information

with service providers, partners, other Match Group companies, and, in some cases, legal

authorities. Here are more details on how your information is shared:

• With other users: You voluntarily share information with other users when you

disclose it on the service, including your public profile. Please exercise caution and

ensure that the content you share is something you are comfortable with being publicly

viewable, as neither you nor we can control what others do with your information once

it is shared. If you choose to limit the audience for certain parts of your profile or

specific content about you, it will be visible according to your settings.

• With our service providers and partners: We work with third parties who assist us

in operating and improving our services. These parties provide services such as data

hosting and maintenance, analytics, customer support, marketing, advertising, payment

processing, and security operations. We may also share limited information, in a hashed,

non-human readable form, with advertising partners. Before engaging any service

provider or partnering with any entity, we conduct a rigorous vetting process, and all

service providers and partners must adhere to strict confidentiality obligations.

• When required by law: We may disclose your information if reasonably necessary

to comply with a legal process, such as a court order, subpoena, search warrant,

government/law enforcement investigation, or other legal requirements. We may also

disclose information to assist in the prevention or detection of crime, subject to

applicable laws, or to protect the safety of any person.

• To enforce legal rights: Information may be shared if it would help mitigate our

liability in an actual or threatened lawsuit, protect our legal rights and the rights of our

users, business partners, or other interested parties, enforce our agreements with you, or

investigate, prevent, or take action regarding illegal activities, suspected fraud, or other

wrongdoing.

• With your consent or at your request: We may seek your consent to share your

information with third parties, and in such cases, we will provide clear reasons for

wanting to share the information.

• Use of non-personal information: We may use and share non-personal

information (information that does not individually identify you) and personal

information in a hashed, non-human readable form under the circumstances described

above. This information may be shared with other Match Group companies and third

parties, including advertisers, for the development and delivery of targeted advertising

on our services and other third-party websites or applications. We may combine this

information with additional non-personal information or personal information collected

from other sources in hashed, non-human readable form. Further details on our use of

cookies and similar technologies can be found in our Cookie Policy.

Please be assured that we take privacy seriously and prioritize the protection of your

information while adhering to applicable laws and regulations.

9. Your rights:

Uninstall: You have the option to stop information collection by uninstalling the app

through the standard uninstall process on your device. However, please note that if you

uninstall the app from your mobile device, the unique identifier associated with your

device may still be stored. If you later reinstall the application on the same device, we

may be able to link this identifier to your previous transactions and activities.

• Accountability: In certain countries, particularly within the European Union, you have

the right to lodge a complaint with the relevant data protection authority if you have

concerns about how we process your personal information. The data protection

authority you can contact for filing a complaint may be the one in your habitual

residence, your place of work, or where we are established.

10. Residents of California:

If you are a California resident, you have the right to request a notice that discloses the

categories of personal information we have shared with third parties for their direct

marketing purposes during the previous calendar year. To request this notice, please

submit your request through the provided email. Please allow 30 days for a response.

For your protection and the protection of our users, we may require you to provide

proof of identity before fulfilling such a request.

11. How We Protect Your Information:

We take extensive measures to protect your personal information from unauthorized

access, alteration, disclosure, or destruction. While we strive to secure your information,

it is important to note that no system can guarantee absolute security, and we cannot

promise that your personal information will always remain secure.

To maintain the security of your information, we continually monitor our systems for

potential vulnerabilities and attacks. We regularly review our information collection,

storage, and processing practices to update our physical, technical, and organizational

security measures.

If we suspect or detect any breach of security, we may suspend your use of all or part of

our services without notice. If you believe that your account or information is no longer

secure.

12. How Long We Retain Your Information:

We retain your personal information for as long as necessary for legitimate business

purposes as outlined in Section 5 and as permitted by applicable law. Upon account

deletion, we implement a safety retention window of three months to protect the safety

and security of our users. During this period, account information will be retained, but it

will no longer be visible on our services.

In general, we delete or anonymize your information after the safety retention window

or after two years of continuous inactivity, unless:

1. Applicable law requires us to retain certain information, such as traffic data, for a

specified period.

2. We need to retain information as evidence of our compliance with applicable law,

such as records of consent to our Terms, Privacy Policy, and similar agreements, which

are kept for five years.

3. There is an ongoing issue, claim, or dispute that requires us to retain the relevant

information until it is resolved.

4. The information needs to be retained for our legitimate business interests, such

as fraud prevention and enhancing user safety and security. For example, information

may be kept to prevent a user who has been banned for unsafe behavior or security

incidents from opening a new account.

Please note that while our systems are designed to delete data according to the above

guidelines, technical constraints may prevent the deletion of all data within a specific

timeframe.

13. Children's Privacy:

Our services are restricted to users between the ages of 13 and 17. We do not permit

users over the age of 18 on our platform. If you suspect that a user is over the age of 18,

please use the reporting mechanism available through the service.

14. Privacy Policy Changes:

As we continuously seek new and innovative ways to facilitate meaningful connections,

this policy may change over time. We will provide notice to you before any material

changes take effect so that you have the opportunity to review the revised policy.

15. How to Contact Us:

If you have any questions, concerns, or inquiries regarding this Privacy Policy or our

privacy practices, please contact us using the contact information provided below:

[email protected]