Last Updated: 25th June 2020
1. WHAT INFORMATION DO WE COLLECT?
We collect the following types of information from you when you interact with our Platform:
A. Personal Information
When you use our website, you may choose to provide certain information directly to us to request more information or services, including the following Personal Information (“Personal Information”):
- email addresses;
- date of birth;
- payment card billing information;
- physical location;
- profile picture;
- telephone and fax numbers; and
- IP addresses.
Additionally, we may collect any of the following information if we are required to verify your identity or process payments:
- passport information;
- mailing address;
- tax-related documents; and
- other government-issued identification.
B. Usage Information
- IP address;
- the type of computer or mobile device you are using;
- platform type (like Apple iOS or Android);
- your operating system version;
- your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
- application performance and de-bugging information;
- your browser type and language;
- referring and exit pages, and URLs;
- the number of clicks on an app feature or web page;
- the amount of time spent on an app feature or web page; and/or
- the date and time of activity on our Platform.
If you access our Platform on a mobile device, in addition to your device identifiers (described above), we may also collect:
- the name you have associated with your device;
- your country;
- your IP address
- your telephone number (if you provide it);
- your specific geolocation (with your permission);
- your mobile contacts (with your permission); and/or
- information about our Platform and other third-party apps you have on your device.
C. Behavioral Information
When you use our Platform, we collect information about the ways in which you use and interact with our Platform, such as when and for how long you use our Platform, Platform features and other users you interact with, purchases you make, and similar activities.
If you choose to use communication features offered by the Platform that allow you to communicate or share information with other users, then we’ll collect information on what is communicated or shared. This includes:
- your participation in user forums and message boards;
- your public posts or comments;
- your non-public messages or invitations to other users made directly through our Platform;
- your chats with other users ; and/or
- your posted photos, drawings, or other user-generated content.
We may access in real-time, record, and/or store archives of these communications, comments, photos, drawings, and other user-generated content on our servers to make use of them to protect the safety and well-being of our users; to protect our rights and property in connection with our Platform; to conduct research; to operate, improve, personalize, and optimize our Platform and our users’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this.
D. Information from Connected Third-Party Applications And Social Networks
We will collect some information from other companies, including social networks, if you access our Platform through your accounts with those companies or you choose to connect your accounts with those companies to our Platform.
If you access services on connected third-party applications or connect our Platform to any third-party applications, including social networks like Facebook, we may receive certain information about you from the provider of the third-party application. The information we receive depends on the service you are using, the third-party application, your privacy settings, and, if applicable, your friends’ privacy settings on that third-party application. For example, we may collect and store some or all of the following information from the provider of the connected third-party application:
- your first and last name;
- your profile picture or its URL;
- your user identification number (such as your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
- your friends’ user ID numbers and other public data;
- the e-mail address you provided to that third-party application;
- your approximate physical location and that of the devices you use to access our Platform;
- your gender;
- your birthday, age, and/or age range;
- information about your activities on or through the connected third-party application;
- other publicly-available information on the third-party application; and/or
- any other information that you or the provider of the third-party application share with us.
If you access our Platform from a third-party application or connect our Platform to a third-party application, you should also read that third-party application’s terms of service and Policy.
If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.
2. HOW DO WE COLLECT YOUR INFORMATION?
We collect Personal Information when you:
- visit or interact with our Platform;
- create an account;
- request information;
- directly provide it to us;
- purchase products or services; and
- participate in surveys, promotional offers, contests, or sweepstakes.
B. Google Analytics
3. WHAT DO WE DO WITH YOUR INFORMATION?
We use your Personal Information to:
- improve and optimize the Platform and our users’ experiences;
- establish and verify the identity of Platform users;
- open, maintain, administer and service users’ accounts or memberships;
- process, service or enforce transactions and send related communications;
- enforcing the terms and conditions of this Platform or other company policies and procedures;
- provide services and support to Platform users;
- improve the Platform, including tailoring it to users’ preferences;
- provide users with updates, notices and offers, and other information about Simfoni;
- respond to your questions inquiries, comments and instructions; and
- maintain the security and integrity of our systems.
Additionally, we may use cookie-based information or other information collected directly from your mobile device to:
- provide you with access to your user preferences, and sign-in on approved devices;
- help diagnose problems with the Platform, administer and improve the Platform, and measure the use of the Platform;
- identify your internet provider, page views and other information regarding utilization of the Platform;
- gather other web analytics information related to your and other users’ use and navigation of the Platform;
- provide you with relevant content, including advertisements and other offers from third parties;
- aggregate cookie data across all users to track overall visitor traffic patterns and provide this aggregated information to vendors, potential advisors, business partners, new agencies, or other parties to identify interests or plan for technical infrastructure requirements;
- conduct advertising based on your use of the Platform, as described below; and
- otherwise provide improvements and enhancements to the Platform.
To the extent we are able to do so, we may link your Personal Information to information we collect that by itself typically cannot be used to identify or contact you, such as demographic information (e.g. age, profession or gender), browser types, domain names, and other anonymous statistical data involving the use of our Platform. We may also link information collected online with information we collect offline or that is collected online by third parties.
4. HOW WE SHARE YOUR INFORMATION
Simfoni may disclose your Personal Information with:
- Your Consent. We may share or disclose your Personal Information with your consent, such as when you use a third party web client or application to access your Simfoni account.
- Third-Party Advertising Including Behavioral Advertising and Analytics. We will share some of your information with advertisers to tailor the advertisements you see when you use our Platform to your particular interests. We use advertising to enable us to offer some of our services for free. These advertisements may include, without limitation, banner ads on the Platform.
- Law and Harm. We may preserve or disclose any of your information, including your Personal Information, if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Simfoni’s rights or property.
Simfoni may also be required to use or disclose your information in connection with a legal action or other proceeding, including without limitation, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.
5. EMAIL OPT OUT
From time to time, you may receive e-mails from Simfoni with news or other information on events, products, services, discounts, special promotions, upcoming events or other offers from or on behalf of Simfoni. If at any time you wish to stop receiving emails or mailings from Simfoni please send us an email to [[email protected]] with the phrase “Privacy Opt-out: Simfoni Mailings” in the subject line, or write to us at the address provided below, and we will remove you from Simfoni’ mailing list. Alternatively, for e-mail communications, you may opt out of receiving such communications by following the unsubscribe instructions set forth at the bottom of most promotional e-mail messages from Simfoni.
6. THIRD-PARTY SERVICES AND SITES
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
A. Social Media Sites
We work with third parties, including social network sites like Twitter, Facebook, YouTube, and Instagram, and with application developers who specialize in social commerce so we can connect to your social networks. All of these companies operate Social Media Sites. We provide access to our Platform by third parties and business partners so we can generate interest in our products among members of your social networks and to allow you to share product interests with friends in your network.
The use of any features made available to you on our Platform by a third party may result in information being collected or shared about you by us or by the third party. Information collected or shared through any such third party features is considered public information by us because the Social Media Sites made it publicly available. If you do not want us to be able to access information about you from Social Media Sites, you must instruct Social Media Sites not to share the information. Simfoni is not responsible for how these third parties may use information collected from or about you so be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a Social Media Platform to share information about you, you must contact that site and determine whether it gives you the opportunity to opt out of sharing such information. However, we do identify any areas on our Platform where third parties share information about you.
We use features on Social Media Sites that allow you to express positive opinions about our products or purchase our products. Those Social Media Sites may collect or register your views about our products (including whether you purchased a product) and make those views available to Simfoni and on public portions of the Social Media Sites. If you do not wish any of this to happen, you should not express your views about our products on Social Media Sites, you should not buy our products through Social Media Sites, and you should review your privacy settings on such Social Media Sites. We are not obligated to display your name or other identifying information, account name, profile photo or other information or content on our Platform even if you express an opinion about one of our products or have consented to our use of such information or content. We reserve the right to remove the information of any person for any reason. We may also remove from our Sites, in our sole discretion, any product offering or any photo or product description relating thereto. If you would like us to delete the data we have collected about you that we have received through any social media provider or Social Media Platform, please contact us. However, if your information is deleted you may not have access to certain promotions, product information or opportunities as a result.
The Platform may list or link to third party products or services. Simfoni does not have any control over the quality, safety or legality of the items advertised, the truth or accuracy of the listings, the ability of suppliers to sell items or the ability of buyers to buy items. For these reasons, Simfoni and its affiliates cannot ensure that a buyer or supplier will actually complete a transaction. Simfoni will not be a party to any transactions between you and such third parties and any correspondence concerning such transactions should be conducted between you and the third party.
To protect your Personal Information, we utilize reasonable technical, physical, and administrative safeguards.
8. CHILDREN’S INFORMATION
The Platform is not directed to children under the age of 13. Children under the age of 13 are prohibited from submitting any personally identifiable information to Simfoni through the Platform. If you believe a child has provided us with information, contact us at [[email protected]].
9. SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS
If you are a California resident, you have the right to request information from us regarding the manner in which Simfoni shares certain categories of Personal Information with third parties for their direct marketing purposes in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
- The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- the names and addresses of the third parties that received the information; and
- if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: [[email protected]].
Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
10. Legal bases for processing personal information
Some laws require companies to tell you about the legal grounds they rely on to process your Personal Information. To the extent those laws apply, we process your personal information:
A. Legitimate Interests
In many cases, we handle Personal Information on the ground that it furthers our legitimate interests’ in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Customer service;
- Protecting our users, employees, and property;
- Analyzing and improving our business;
- Processing job applications; and
- Managing legal issues.
B. Other Bases
- We may also process Personal Information for the legitimate interests of our affiliates or business partners, such as to offer special events or contests or assist with marketing.
- Processing for the Contract. Some of our processing of Personal Information is to meet our contractual obligations with our players.
- Consent. Where required by law, and in some other cases, we handle Personal Information on the basis of your implied or express consent.
- Legal Compliance. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
11. QUESTIONS AND CONTACT INFORMATION
If you have any questions or would like to request the right access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply want more information contact us at [[email protected]] or by mail at: