Privacy policy

Welcome to our app and/or website (the “App”). This App is operated by Spread-Kindness Limited, referred to as “we” or “us” or “our”.

We collect, use and are responsible for certain personal information about you. When we do so we are responsible as ‘controller’ of that personal information.

This privacy policy (the “Privacy Policy”) explains our practices regarding your personal data, including your choices regarding the collection, use, and disclosure of certain information by us.

Within our App you may find outbound links to websites owned and operated by third parties. These websites have their own privacy policies and you should review these as only they are liable for the use and security of the data that you provide to them.

Your Rights

You have the following rights regarding your information:

Rights	What does this mean?
The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.
The right of access	You may have the right to obtain access to your information (if we’re processing it), and other certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification	You may be entitled to have your information corrected if it’s inaccurate or incomplete.
The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you, in certain circumstances, to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing	You may have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability	You may have the right to request that your personal data be transferred to you or another person or organisation.
The right to object	You may have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).

If you would like to exercise any of those rights, or to ask a question, please:

• email us at privacy@soulbuddy.com;
• let us have enough information to identify you and verify your identity; and
• let us know the information to which your request relates.

Generally, we will respond within one month from when we receive your request.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• manifestly unfounded or excessive requests; or
• further copies of the same information.

Collection of Information

We collect personal information about you, either directly (for example, when you register for a profile with us, contact us, or send us feedback) or indirectly (for example, when you browse our App).

We collect, receive and store the following information about you:

• your username and contact number. This information is required from you to enable us to provide access to content on the App;
• your full name, email address, gender, age, location (by country or city), and hobbies. This information is optional and you may choose to provide these details if you would like us to better tailor your experience on the App;
• your mobile device metadata (including device type, device operating system (including version), whether you are using WiFi or cellular, IP address, and GSM carrier;

• your activity on our customer portal(s), last log-in and requests; and
• details of your interaction(s) with our team, such as the date, time, reason for contacting us and resolution.

Use of Information

We use information to:

• provide you with access to the App and the content on the App;
• help us quickly and efficiently respond to inquiries and requests;
• communicate with you regarding our service so that we can send you news, surveys, and prizes and assist you with operational requests such as password reset requests;

• carry out our obligations to provide you with the information, products and services relating to the service that we are contracted to carry out;
• carry out admin tasks on our App and for internal operations, including troubleshooting, app safety, security and analytics;
• notify you of any changes to our App or the content on our App; and
• satisfy legal obligations, fraud prevention, or establish, exercise or defend a legal claim.

We do not carry out automated decision making using your personal data.

Legal Bases for Processing

The legal bases on which we rely when processing your personal data are:

• consent: where you have given us consent for us to process your personal information for a specific purpose. You may withdraw your consent at any time by emailing us at [support@soulbuddy.com]. However, please note that, without your consent, the services which we are able to offer you may be affected;
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations) or establish, exercise or defend legal claims; or
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (except where such legitimate interests are overridden by your own interests, rights, or freedoms which require the protection of personal data). Where we intend to rely on legitimate interests as our legal basis for processing, we will conduct a legitimate interest assessment to ensure that such processing isn’t overridden by your interests, rights, or freedoms. Our legitimate interests are providing you with access to the App and the content on the App. Where we have relied on our legitimate interests to process your personal information, you may contact us to obtain more information, including in relation to our assessment of the impact on you.

Disclosure of Information

We may share your personal information with:

• third party service providers who undertake services on our behalf or to assist us; and
• law enforcement or other authorities.

In addition, we and/or our service providers may disclose and otherwise use your personal and other information where disclosure is needed to:

• satisfy any applicable law, regulation, legal process or governmental request;
• enforce applicable terms of use;
• detect, prevent, or address illegal or suspected illegal activities (including payment fraud), security or technical issues; or
• provide disclosures in connection with the acquisition, merger or sale of our business; or
• protect against harm to the rights, property or safety of our business, other users of our services, or the public, as required or permitted by law.

Transfer of your information out of the EEA

Generally, we do not transfer your personal information to any third parties which are located outside the United Kingdom (UK) or European Economic Area (EEA). However, we do work with one third party service provider which is based in Israel and which may have access to your information for the purposes of developing the App. The European Commission has recognised Israel as providing an adequate level of data protection (meaning that personal data can flow between us and our service provider in Israel without any further safeguard being necessary).

Your Choices

If you no longer want to receive certain communications (other than service notifications) from us via email or text, then you can: (1) unsubscribe from such communications by clicking the “unsubscribe” button in any email addressed to you; or (2) email us at support@soulbuddy.com and we will remove you from the list.

How long your personal information will be kept

We will hold your personal information:

• for as long as we provide access to the App to you; or
• where we are required to do so in line with legal and regulatory requirements or guidance.

Changes to This Privacy Policy

This Privacy Policy will be updated from time to time in order to comply with legal, regulatory or operational requirements. You should check this Privacy Policy regularly in order to be aware of such updates. To see when this Privacy Policy was last updated, please see the “Last Updated” section below.

Cookies and Internet Advertising

To provide better service to you on the App, we use cookies to collect your personal information when you browse. See our Cookies Policy for more details.

Contacting Us

For any questions regarding your account, data, usage of cookies, this Privacy Policy, or for a copy of our complaints procedure, please contact us by email at privacy@soulbuddy.com.

If you wish to find out more about your rights and the legislation, or if you would like to make a complaint, you can do so by contacting the relevant supervisory authority as follows:

• the supervisory authority in the UK is the Information Commissioner and can be contacted here or by telephone on +44 303 123 1113; and
• the supervisory authority in Cyprus is the Office of the Commissioner of Personal Data and can be contacted here or by telephone on +357 2281 8456.

Last update

This Privacy Policy was last updated on August 14, 2020.