Privacy Policy

Privacy Policy, last modification: April 14, 2020
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Springchat Ltd is the controller and responsible for your personal data (collectively referred to as "Springchat", "we", "us" or "our" in this Privacy Policy).

The basic purpose of this Privacy Policy is to give you information on how Springchat collects and processes your personal data through your use of our website or the Springchat App (“Services”), including any data you may provide through use of our Services.

Our Services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

We believe you should always know what data we collect from you and how we use it and in order to empower you to make the best decisions about the information that you do share with us, we believe you should have meaningful control over both.

Please read this Privacy Policy in full but to start with, here are the few key things you should take away from it:
  • The data we collect about you. Very little personal information is required for setting up a user account on Springchat. In order to use our Services, the only information we require is your name, a Username, a valid email address and your age.
  • How we use your personal data. Apart from your Username, you have full control over what other public information others can see in the Springchat App. In addition to the information you share with us, we use the content you’ve read, shared or joined into an Instant Chat to, and other information to determine what topics you’re interested in, your age, the languages you speak, and other signals to show you more relevant content.
  • Managing your personal data. If you have questions about this policy, how we collect or process your personal data, how you can exercise your rights or anything else related to our privacy practices, we want to hear from you. You can contact us at any time.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. The Personal Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes your address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose (including but not limited to selling to third parties). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or anonymise your personal data so that your identity cannot be established (whether directly or indirectly). However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to terminate your account but we will notify you if this is the case at the time.

2. How Your Information is Collected and Used by Us

Springchat will require certain information in order to enable us to provide our Services to you. For example, you must have an account with us in order to consume or share content on Springchat. When you choose to share the information below with us, we collect and use it to operate our Services.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

2.1. Basic Account Information

In order to create an account, you must provide us with some personal data so that we can provide our services to you. On Springchat, this includes a Display Name (for example, “Jerry Springer”), a Username (for example, “JerrySpringer), a password, an email address and your age. Providing a phone number is optional. Your Username is always public, but you can use either your real name or a pseudonym.

2.2. Public Information

Most activity on Springchat is carried out anonymously; where only your username will be immediately public. Other information, such as your display name and the content you have read will only be available to the Friends you have connected with and if your privacy settings are set to display this information. Your location, time zone, gender, email address, phone number, interests and other Springchatters you have in your contacts list will never be displayed publicly.

It is important to note that it is your choice whether to include sensitive information (which would fall under Special Categories of Personal Data as stated above) on your profile and to make that sensitive information public. Please do not post or add such personal data to your profile that you would not want to be publicly available.

2.3. Contact Information and Address Book

We use your contact information, such as your email address or phone number, to authenticate your account and keep it - and our Services - secure, and to help prevent spam, fraud, and abuse. We also use contact information to personalize our services, enable certain account features (for example, for login verification, and to send you information about our services. If you provide us with your phone number, you agree to receive text message notifications from Springchat to that number as your country’s laws allow. You can use your settings for email and mobile notifications to control notifications you receive from Springchat. You can also unsubscribe from a notification by following the instructions contained within the notifications.

You can choose to upload and sync your address book on Springchat so that we can help you find and connect with people you know and help others find and connect with you. We also use this information to better recommend content to you and others.

If you email us, we will keep the content of your message, your email address, and your contact information to respond to your request.

2.4. Direct Messages and Non-Public Communications

We provide certain features that let you communicate more privately or control who sees your content. For example, you can use Direct Messages to have non-public conversations with your Friends on Springchat. When you communicate with others by sending or receiving Direct Messages, we will store and process your communications and information related to them. This may include link scanning for malicious content, link shortening to http://t.co URLs, detection of spam and prohibited images, and review of reported issues. We also use information about whom you have communicated with and when (but not the content of those communications) to better understand the use of our services, to protect the safety and integrity of our platform, and to show more relevant content. We share the content of your Direct Messages with the people you’ve sent them to; we do not use them to serve you ads. Any direct messages or media shared will be through encryption in-transit and stored on the Springchat’s servers indefinitely with encryption at-rest. When you use features like Direct Messages to communicate, remember that recipients have their own copy of your communications on Springchat even if you delete your copy of those messages from your account - which they may duplicate, store, or re-share.

2.5. How You Control the Information You Share with Us

Your Privacy and Safety Settings let you decide:
  • Whether your Display Name is publicly visible.
  • Whether others can find you based on your email or phone number.
  • Whether you upload your address book to Springchat for storage and use.
  • Whether you want to block or mute other Springchat accounts.

2.6. Location Information

When you sign up to Springchat, we will collect your location information, which we get from signals such as your IP address or device settings. This is to securely and reliably set up and maintain your account and to provide our Services to you.

Subject to your settings, we may collect, use and store additional information about your location to operate or personalize our Services to you with more relevant content like, for example, local trends and news content.

2.7. Links

In order to operate our Services, we keep track of how you interact with links across our Services. This includes the links in your content newsfeed and any external third-party links that you may click on.

Springchat has no control over the personal information that will be requested or collected (such as, for example, cookie identifiers or your IP address) by a third-party website or application if you click on an external third-party link though any of the Springchat Services.

2.8. Log Data

We receive information when you view content on or otherwise interact with our Services, which we refer to as “Log Data”. If you use or interact with any of our Services, we may receive information about the following:
  • When you start a new session online.
  • How long your session lasts.
  • What content you have viewed during that session.
  • How long you have spent on each piece of content.
  • What category the content you viewed was in and any keywords associated with that content.
  • Whether you initiate to join an Instant Chat.
  • Whether you successfully joined an Instant Chat.
  • How many Instant Chats you participated in during that session.
  • Whether you clicked on any external third-party links.
  • Information about the device you are accessing our Services from (for example, device model, device operating system).
We use Log Data to operate our services and ensure their secure, reliable, and robust performance. For example, we use Log Data to protect the security of accounts and to determine what content is popular on our services. We also use this data to improve the content we show you. We use information you provide to us and data we receive, including Log Data, to make inferences like what topics you may be interested in, how old you are, and what languages you speak. This helps us better design our services for you and personalize the content we show you.

3. Information We Share and Disclose

Springchat is designed to be a place to chat with others as anonymously as possible. However, in the limited circumstances where we disclose your private personal data, we do so subject to your control, because it’s necessary to operate our services, or because it’s required by law.

3.1. Non-Personal Information

We share or disclose non-personal data derived from our Instant Chat Service, such as aggregated information like the total number of people engaging in an Instant Chat about the same piece of content, and sentiment related to. the topics Springchatters are talking about in the Instant Chats. We do not use this information to target ads to you.

3.2. Law, Harm and the Protection of Public Interest

We may collect, preserve, use and share your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to protect the safety or integrity of our platform and Services, including to help prevent spam, abuse, or malicious actors on our services, or to explain why we have removed content or accounts from our services; to address fraud, security, or technical issues; or to protect our rights or property or the rights or property of those who use our Services.

3.3. Affiliates and Change of Ownership

In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity. We may also disclose personal data about you to our corporate affiliates in order to help operate our Services and our affiliates’ services.

4. Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

5. Managing Your Personal Information with Us

Apart from the information required to create an account and to use our Services, you have control over the amount of personal data you share with us. You have the control to deactivate or terminate your account with us and withdraw consent where applicable to the data you have provided to Springchat.

We have appointed a data privacy manager] who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (as set out above), please contact the data privacy manager using the details set out below.

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

5.1. How Long Will We use Your Personal Data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights above for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely for whatever purpose without further notice to you.

6. Third-Party Content

Our Services may include links to third-party websites, services or products ("Third-Party Content"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Third-Party Content is not under our control and are not responsible for their privacy statements, website, contents, products or services. When you leave our Services to access Third-Party Content, we encourage you to read the privacy policy of every website you visit.

6.1. Information Collected by Third Parties

Springchat displays some linked content from Twitter and YouTube and utitlises YouTube API Services for providing content on our Services. Springchat does not control how third-party services collect data when they serve you this content in Springchat and as a result, is not covered by Springchat's privacy policy.

By accessing content provided by YouTube API Services on our Services, you are agreeing to the terms set out in the Google Privacy Policy.

7. Changes to this Privacy Policy

We may revise this Privacy Policy when we deem necessary to do so. The most current version of the policy will govern our processing of your personal data and will always be here. If we make a change to this policy that, in our sole discretion, is material, we will notify you via an email update to the email address associated with your account. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.