OUR PLEDGE TO YOU
At Soshel, safeguarding your privacy is of utmost importance. We prioritize your privacy in the design and development of the services and products you know and cherish, ensuring that you can trust them and focus on fostering meaningful connections.
We deeply value the trust you place in us by providing your information, and we take this responsibility seriously.
Our Dedication to Privacy: Our products and services are meticulously designed with your privacy in mind. We engage experts from various domains, including law, security, engineering, and product design, to ensure that our decisions consistently uphold the highest regard for your privacy.
Our Commitment to Transparency: Recognizing the common issues of insufficient information and convoluted language in privacy policies, we take the opposite approach. We strive to present our Privacy Policy and related documents in clear, straightforward language. Our intention is for you to read and comprehend our policies, enabling you to fully grasp our privacy practices.
Our Focus on Security: We maintain dedicated teams focused on safeguarding and securing your data. Continually updating our security measures, we invest in robust security efforts to enhance the protection of your information.
PRIVACY POLICY
Welcome to the Privacy Policy of Soshel. Thank you for taking the time to review it.
For residents of California, please refer to our California Privacy Statement, which supplements this Privacy Policy.
We value the trust you place in us by sharing your information, and we are committed to maintaining
that trust. To begin, we want to ensure that you have a clear understanding of the information we collect, why we collect it, how it is utilized, and the choices you have regarding your information. This Policy provides a straightforward explanation of our privacy practices, minimizing the use of legal and technical terminology.
This Privacy Policy is effective as of February 15, 2023. The previous version of this Privacy Policy, accessible here, will remain in effect until that date.
Our Identity
For individuals residing in the United States the entity accountable for your information as outlined in this Privacy Policy is:
Soshel LLC.
7901 4th St N, STE 4000
St. Petersburg, FL 33702
Scope of this Privacy Policy
This Privacy Policy pertains to the websites, applications, events, and other services offered under the Soshel brand. For simplicity, we refer to all of these collectively as “services” in this Privacy Policy. To ensure clarity, we have provided links to this Privacy Policy on all applicable services.
Certain services may have their own distinct privacy policies. If a service has its own privacy policy, that policy takes precedence over this Privacy Policy.
Information We Collect
It is essential for us to have some information about you in order to facilitate the development of meaningful connections. This includes basic profile details and preferences regarding the types of individuals you would like to meet. Additionally, we collect information about your usage of our services, such as access logs. We may also obtain information from third parties, such as when you access our services through your social media account or import information from your social media account to complete your profile. For more detailed information, please refer to the following sections.
Information Provided by You
When utilizing our services, you have the option to provide us with specific information. This may include:
Account Creation: When you create an account, you provide us with at least your phone number and email address. Additionally, you provide basic details required for the functionality of the service, such as your gender, date of birth, and preferred connections.
Profile Completion: When completing your profile, you have the choice to share additional details with us, such as your sexual orientation, ethnicity, religious beliefs, and political opinions. By providing such information, you consent to its use for the purposes outlined in this Privacy Policy. You can also share supplementary information, including bio details, interests, and content such as photos, videos, and audio clips. To include certain content like pictures or videos, you may grant us access to your camera, photo album, or microphone.
Paid Services and Purchases: If you subscribe to a paid service or make a direct purchase from us (rather than through platforms like iOS or Android), you provide us with relevant information related to your transactions, and our payment processors receive details such as your debit or credit card number or other financial information.
Surveys and Market Studies: When participating in surveys, focus groups, or market studies, you provide us with insights into our products and services, responses to questions, and testimonials.
Promotions, Events, and Contests: If you choose to participate in our promotions, events, or contests, we collect the information required for registration or entry.
Customer Interaction: When you contact us, such as through our customer care team or on social media, we collect the information you provide during the interaction.
Sharing Information about Others: If you share information about other individuals (e.g., using a friend’s contact details for a specific feature), we process that information on your behalf to fulfill your request.
Additionally, we process your conversations with other users and the content you publish to operate and secure our services and ensure the safety of our community.
Information Received from Others
In addition to the information you directly provide us, we also receive information about you from various sources, including:
Users
Other users of our services may provide information about you as they interact with you or report incidents involving you.
Social Media
You have the option to share information with us through your social media accounts. For example, you may choose to create or log into your Soshel account using your social media or other accounts (such as Facebook, Google, or Apple), or upload photos from your social media accounts (such as Facebook or Instagram) onto our services.
Other Partners
Our partners who display our advertisements on their services may provide us with information about you. In some cases, they may share details about the success of advertising campaigns. Additionally, we may receive information about suspected or convicted individuals who pose a risk to our users’ safety and security from third parties, where legally permissible.
Information Generated or Automatically Collected during Service Usage
When you use our services, certain information is generated or automatically collected regarding your usage and the devices you utilize to access our services. Here are further details:
Usage Information
Using our services generates data related to your activities, such as when you logged in, the features you’ve used, actions taken, information displayed to you, referring webpage addresses, ads you interacted with, and your interactions with other users (such as connections, messages, and matches).
Device Information
We collect information about the device(s) you use to access our services, including hardware and software details like IP address, device ID, device type, app settings, app crashes, advertising IDs (randomly generated numbers that can be reset or disabled in device settings), and identifiers associated with cookies or other technologies that uniquely identify a device or browser.
Information Collected through Cookies and Similar Technologies
We employ cookies and similar technologies (e.g., web beacons, pixels, and SDKs) to recognize you and/or your device(s). For more information on the use of cookies and how you can control them, please refer to our Cookie Policy.
It’s important to note that the “Do Not Track” (DNT) feature available in certain web browsers (such as Safari, Internet Explorer, Firefox, and Chrome) may indicate a user’s preference to not have their online activity tracked. However, DNT signals are not yet standardized, and not all browsers offer this option. Therefore, at present, many businesses, including Soshel, do not specifically respond to DNT signals.
Other Information with Your Consent
With your explicit consent, we may collect additional types of information, including:
Precise Geolocation Data
If you grant us permission, we can collect your precise geolocation (latitude and longitude) from your device. This collection may occur in the background, even when you’re not actively using our services, provided you have explicitly allowed it. If you decline permission for us to collect your precise geolocation, we will not gather this information, and certain services reliant on precise geolocation may not be available to you.
Selfie Verification Data
If you choose to participate in our Selfie Verification feature, we collect your face geometry data, which may be considered biometric data in certain jurisdictions. This data is used to verify your identity. You can find more information about Selfie Verification and the processing of your face geometry data in our dedicated resources.
Other Information
We may collect additional information with your consent, such as photos, videos, or participation in streaming features on
How We Use Information
Our primary purpose in using your information is to deliver and enhance our services. Additionally, we employ your information to ensure your safety and the safety of our community, as well as to provide you with relevant advertising. Below, we provide a detailed explanation of how we use your information, along with practical examples:
- Administering your account and providing services:
Creating and managing your account
Offering customer support and addressing your inquiries Communicating with you regarding our services
Personalizing pricing, offering discounts and promotions, and facilitating transactions Managing sweepstakes and contests
- Facilitating connections with other users:
Recommending you to other users and vice versa Displaying users’ profiles to one another
Enabling users to search for and connect with one another
- Providing offers and conducting advertising and marketing campaigns:
Performing and evaluating the effectiveness of advertising campaigns on our platform and through
external marketing channels
Informing you about products or services that may interest you
- Improving and developing our services:
Conducting focus groups, market studies, and surveys Analyzing customer care interactions to enhance service quality
Understanding user behavior patterns to improve our services (e.g., modifying features based on user feedback)
Developing new features and services based on user requests
- Preventing, detecting, and combating fraud and unauthorized activities:
Identifying and addressing ongoing or suspected violations of our Terms of Use, including reviewing reports and user interactions
Enhancing our understanding of violations and implementing countermeasures Retaining data related to violations to prevent future occurrences
Enforcing our rights and exercising legal measures, such as those outlined in our Terms of Use Communicating with individuals who report incidents and informing them of our actions
- Ensuring legal compliance:
Adhering to legal requirements
Assisting law enforcement agencies
For information on how we process personal data through profiling and automated decision-making, please refer to our FAQ.
To process your information as described in this Privacy Policy, we rely on the following legal bases:
Providing our service to you: Processing your information for purposes A and B is necessary to fulfill the contract between you and us. This includes maintaining your account, making your profile visible to others, recommending potential connections, and providing both free and paid features.
Legitimate interests: Processing your information for purposes C, D, and E is based on our legitimate interests. This involves analyzing user behavior to enhance our services, suggesting relevant offers, ensuring user safety, and protecting our rights and interests in legal situations.
Compliance with applicable laws and regulations: Processing your information for purpose F is necessary to comply with relevant laws and regulations and to demonstrate our adherence to them. For instance, we retain data related to transactions for accounting and tax obligations and respond to valid law enforcement requests. We also retain evidence of user consents and opt-out decisions.
Consent: When you provide us with “special” or “sensitive” information, such as your sexual orientation, you consent to our processing of that information in accordance with this Privacy Policy. Occasionally, we may seek your consent for specific data collection or usage purposes. You have the right to withdraw your consent by adjusting your settings or deleting relevant content. Contact us at the provided address in this Privacy Policy to withdraw consent.
How We Share Information
Our primary purpose is to facilitate meaningful connections, and as such, we share users’ information with other users. Additionally, we share certain user information with our service providers, partners, and, in certain cases, legal authorities. Please continue reading for a detailed explanation of how your information is shared with others.
Sharing with Other Users:
You share information with other users when you willingly disclose it on our platform, including your public profile. We advise you to exercise caution and only share content that you are comfortable being visible to others. If you choose to limit the audience for specific parts of your profile or certain content, the visibility will be adjusted according to your settings. In situations where someone reports an issue involving you, such as a violation of our Terms of Use, we may communicate the actions we have taken to address the report.
Sharing with Service Providers and Partners:
We engage vendors to assist us in operating, distributing, marketing, and improving our services. These vendors provide services such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations. We may also share information with vendors who help us advertise our services. For instance, we may share limited, non-human readable information about you with advertising vendors. Before partnering with any vendor or service provider, we undergo a rigorous vetting process, and they are required to adhere to strict confidentiality obligations.
Sharing with Affiliates:
Soshel shares your information with our affiliates for specific legitimate purposes, including:
Assisting us in data processing operations as processors or service providers, according to our instructions and on our behalf. These operations may include tasks like data hosting, maintenance, customer care, marketing, targeted advertising, analytics, finance and accounting assistance, service improvement, data and system security, as well as combating spam, abuse, fraud, infringement, and other unauthorized activities.
Sharing in Corporate Transactions:
If we are involved, in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or any other ownership or control change, we may transfer your information as part of that transaction.
Sharing with Law Enforcement and when Required by Law:
We may disclose your information if reasonably necessary to:
Comply with legal processes, such as court orders, subpoenas, search warrants, government or law enforcement investigations, or other legal requirements.
Assist in the prevention or detection of crime, subject to applicable laws. Protect the safety of any person.
Sharing to Enforce Legal Rights:
We may share information to:
Mitigate our liability in actual or potential lawsuits.
Protect our legal rights, as well as the rights of our users, business partners, or other relevant parties. Enforce our agreements with you.
Investigate, prevent, or take action against illegal activities, suspected fraud, or other wrongdoing. Sharing with Your Consent or at Your Request:
In certain cases, we may ask for your consent to share your information with third parties. We will always provide a clear explanation of why we need to share the information.
Use of Non-Personal Information and Personal Information in Hashed Form:
We may use and share non-personal information, such as device information, general demographics, and general behavioral data that does not identify you individually. Additionally, we may share personal information in hashed, non-human readable form under the circumstances mentioned above.
Transfers of Data Across Borders
The sharing of information described in Section 5 may involve the transfer of data to the United States of America and other jurisdictions with differing data processing laws. When we transfer personal information outside the European Economic Area (EEA), the United Kingdom, Switzerland, or countries deemed to have adequate data protection laws by the European Commission or other competent governmental body, we utilize standard contract clauses or other appropriate transfer mechanisms. We are currently reviewing data transfers to our vendors and assessing the legal basis for these transfers in light of the recent ruling by the Court of Justice for the European Union regarding the transfer of personal data to the USA.
Your Rights and Choices
We want you to have control over your information, so we would like to remind you of the following options and tools available to you:
Access/Update Tools: Within the service, you can utilize tools and account settings to access, correct, or delete the information associated with your account directly. If you need assistance with these tools and settings, please reach out to our customer care team.
Device Permissions: Mobile platforms may have permission systems for specific types of device data and notifications, such as contacts, photos, location services, push notifications, and advertising identifiers. You can modify your device settings to provide or withdraw consent for the collection, processing, or display of such information or notifications. Please note that altering these settings may affect the functionality of certain services.
Uninstall: You can stop all information collection by uninstalling an app through the standard uninstall process on your device. It’s important to remember that uninstalling an app does not close your account. To close your account, please use the relevant functionality provided by the service.
Account Closure: You can close your account by using the designated functionality directly on the service.
We also want you to be aware of your privacy rights, which may vary depending on your location. You may have the right to:
Access/Know: You can request a copy of the information we hold about you and, in certain cases, receive it in a portable format. You can make an access request directly within the service by submitting a request.
Delete/Erase: You may request the deletion of your personal information held by us. You can exercise your right to delete by submitting a request.
Correct/Rectify/Update: Most of the information you provided can be corrected by editing your profile directly within the service. If you believe that the information we have is inaccurate, you can contact us to rectify it.
Object/Restrict: You may have the right to object to or request the restriction of certain processing activities. To exercise this right, please contact us.
For your protection and the protection of all users, we may require proof of identity before fulfilling the above requests. Please note that we may reject requests if we are unable to verify your identity, if the request is invalid or unlawful, or if it infringes on trade secrets, intellectual property rights, privacy rights, or the rights of others. If you wish to receive information regarding another user, such as copies of messages received through our service, that user must submit a separate request to us. We may ask them to provide proof of identity before fulfilling the request. Additionally, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, especially if it impedes our ability to provide the service, such as age verification for users under 18 years old.
If you are a resident of Virginia, USA, and your privacy request is denied, you may have the option to appeal by contacting us and explicitly referencing “Privacy Request Appeal.” If you have concerns about the outcome of your appeal, you may contact the attorney general of your state.
Retention of Your Information
We retain your personal information for as long as it is necessary for legitimate business purposes, as outlined in Section 4, and as permitted by applicable law. If you decide to discontinue using our services,
you have the option to close your account, which will make your profile no longer visible to other users. It’s important to note that if your account remains inactive for a period of two years, we will automatically close it. After your account is closed, we will proceed with the deletion of your personal information according to the following guidelines:
To ensure the safety and security of our users, we maintain a safety retention window of three months following the closure of your account. During this period, we retain your information in case it becomes necessary to investigate any unlawful or harmful activities. The retention of information during this safety retention window is based on our legitimate interest and the potential interests of third-party victims.
Once the safety retention window expires, we delete your data and only retain limited information for specific purposes as described below:
- Legal data retention obligations: We retain limited data to comply with legal requirements for data retention. Specifically, transaction data is retained for 10 years to fulfill tax and accounting obligations. Additionally, we may need to retain “traffic data” or logs for one year to comply with legal data retention obligations. We also keep records of user consents for five years as evidence of our compliance with applicable laws.
- Legitimate interest: We retain limited information based on our legitimate interest. This includes customer care records and supporting data, imprecise location information related to downloads/purchases for customer care decision-making, enforcement of our rights, defense against potential claims, profile data in anticipation of potential litigation, and data necessary to prevent banned users or individuals found to be under 18 years old from opening new accounts. This information is retained for as long as necessary to ensure the safety and vital interests of our users.
- Outstanding or potential issues, claims, or disputes: We retain information based on our legitimate interest when there is an outstanding or potential issue, claim, or dispute that requires us to retain the data. This may include situations where we receive a valid legal subpoena or request to preserve data, in which case we must comply with our legal obligations. We may also retain data if it is otherwise necessary for legal proceedings.
Prohibition of Minors
Our services are exclusively intended for individuals who are 18 years of age or older. We do not permit
individuals under the age of 18 to use our platform. If you suspect that a user is under the age of 18, please use the reporting mechanism provided on the service to bring it to our attention.
Job Candidates, Contractors, and Vendor Representatives
We collect and process personal information of individuals who apply for jobs, work as contractors, or represent vendors as part of our recruitment, talent management, and contractor/vendor management activities. If you fall into one of these categories (job candidate, contractor, or vendor representative) at Soshel, certain relevant terms of this Privacy Policy apply to the processing of your personal information. These terms include sections that discuss the entity responsible for processing your information, transfers of personal information, your rights under applicable law, how to contact us, and information specific to California residents.
If you are a job applicant, the personal information we process about you may vary depending on the position you are seeking. Typically, it includes the information you provide as part of your job application, as well as professional qualifications, background details, and reference information that recruiters or third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. For contractors and vendor representatives, we may process identification information and work-related details necessary to manage our relationship with you and your employer. This processing is essential for performing the services agreement and establishing, exercising, or defending potential legal claims. We may share personal information with service providers who assist us with recruitment and technical data processing operations. We retain your personal information only for as long as necessary to fulfill these purposes.
Changes to the Privacy Policy
As we constantly seek new and innovative ways to help you forge meaningful connections, we strive to keep our explanations of data practices up to date. Therefore, this policy may change over time. Rest assured, we will notify you before any material changes to the policy take effect so that you have an opportunity to review them.
How To Contact Us
If you have any questions about this Privacy Policy, you have several options to contact us at: support@soshel.org