To fulfill our commitment to respecting and protecting your privacy, we will adhere to our basic principles as
- We inform you of the personal information that will be collected, and seek your consent to collect, use, or
disclose your personal information.
- We identify the purposes of use for collecting your personal information.
- We collect only information that is necessary to carry out the identified purposes of use.
- We use or disclose your personal information only for the purposes for which it is collected, except with your
consent or as required or permitted by law, and we will keep your information only as long as necessary to fulfill
- We endeavor to make sure that your personal information is accurate, complete, and up-to-date.
- We protect your personal information via appropriate security safeguards.
- We make our policies and practices for the handling of your personal information as transparent as possible.
- You will have access to your personal information and will be able to correct your personal information as
- We will be accountable to you. We are always interested in hearing your opinion regarding our compliance with
- (1) We appreciate that you trust us with your information and we intend to always keep that trust. This starts
with making sure you understand the information we collect, why we collect it, how it is used and your choices
regarding your information. This Policy describes our privacy practices in plain language, keeping legal and
technical jargon to a minimum.
- (3) EFFECTIVE DATE: May 25, 2018
2. INFORMATION WE COLLECT
It goes without saying, we can’t help you develop meaningful connections without some information about you, such
as basic profile details and the types of people you’d like to meet. We also collect information generated as you
use our services, for example access logs, as well as information from third parties, like when you access our
services through a social media account. If you want additional info, we go into more detail below.
1) Information you give us
You choose to give us certain information when using our services. This includes:
- When you create an account, you provide us with at least your login credentials, as well as some basic details
necessary for the service to work, such as your gender and date of birth.
- When you complete your profile, you can share with us additional information, such as details on your
personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To
add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the
information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for
example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this
information, you consent to our processing of that information.
- When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such
as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit
card number or other financial information.
- When you participate in surveys or focus groups, you give us your insights into our products and services,
responses to our questions and testimonials.
- When you choose to participate in our promotions, events or contests, we collect the information that you use
to register or enter.
- If you contact our customer care team, we collect the information you give us during the interaction.
Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
- If you ask us to communicate with or otherwise process information of other people (for example, if you ask us
to send an email on your behalf to one of your friends), we collect the information about others that you give us
in order to complete your request.
- Of course, we also process your chats with other users as well as the content you publish, as part of the
operation of the services.
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
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 Login) to create and log into your Sweet
Selfie account. This saves you from having to remember yet another user name 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 Sweet Selfie ads are published on a
partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
- • Read the Contents of SD Card
Read, Modify or delete the contents of your SD card as your instructions. We use this permission so that you
can save new pictures to your SD card.
- • Location Information
When you use our services we may collect information about your location. With your consent, we may also
collect information about your precise location using methods that include GPS, wireless networks, cell towers,
Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
3) Information collected when you use our services
When you use our services, we collect information about which features you’ve used, how you’ve used them and the
devices you use to access our services. See below for more details:
- • Usage Information
We collect information about your activity on our services, for instance how you use them (e.g. date and time
you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring
webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect
and interact with, time and date of your exchanges, number of messages you send and receive).
- • Device Information.
We collect information about your device, including the hardware model, operating system and version, unique
device identifiers (including MAC address and IMEI), browser type and language, mobile device phone number, and
mobile network information. We also collect certain device information that will help us diagnose problems in the
(hopefully rare) event you experience any crash or other problem while using our Services. So, for example, if we
detect a crash or other problematic event, we may collect the list of apps on your device and other information
about your device’s performance at the time of the event for troubleshooting purposes.
- • Camera and Photos.
Many of our services require us to collect images and other information from your device’s camera and photos.
We’ll access your camera and photos only after you give us your consent.
3. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
stored on your hard drive or in device memory that store information about your use of the Services, which
authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and
measuring the effectiveness of advertising campaigns, allowing you to use social features. Web beacons are small
pieces of software on a webpage or email that help us see how you interact with that webpage or email. Most web
browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove
or reject browser cookies. Keep in mind, though, that removing or rejecting cookies could affect the availability
and functionality of our Services.
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools
collect information sent by your device or our Service, including the web pages you visit, add-ons, and other
information that assists us in improving the Service. We collect and use this analytics information with analytics
information from other users so that it cannot reasonably be used to identify any particular individual User.
And we use third-party advertising agencies to place advertisements on the Internet or in other media. To measure
the effectiveness of the advertisements and determine how much to pay to the advertising agencies, we install
third-party modules within the App. We may also install third-party modules within the App in order to help us
understand how the Service is used.
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature
that tells a website that a user does not want to have his or her online activity tracked. If a website that
responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain
information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For
this reason, many businesses, including Sweet Selfie, do not currently respond to DNT signals.
4. HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to
help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed
explanation of the various reasons we use your information, together with practical examples.
1) To administer your account and provide our services to you
- • Create and manage your account
- • Provide you with customer support and respond to your requests
- • Complete your transactions
- • Communicate with you about our services, including order management and billing
2) To help you connect with other users
- • Analyze your profile and that of other users to recommend meaningful connections
- • Show users’ profiles to one another
3) To ensure a consistent experience across your devices
- • Link the various devices you use so that you can enjoy a consistent experience of our services on all of
them. We do this by linking devices and browser data, such as when you log into your account on different devices
or by using partial or full IP address, browser version and similar data about your devices to help identify and
4) To provide new Sweet Selfie services to you
- • Register you and display your profile on new Sweet Selfie features and apps
- • Administer your account on these new features and apps
5) To serve you relevant offers and ads
- • Administer sweepstakes, contests, discounts or other offers
- • Develop, display and track content and advertising tailored to your interests on our services and other sites
- • Communicate with you by email, phone, social media or mobile device about products or services that we think
may interest you
6) To improve our services and develop new ones
- • Administer focus groups and surveys
- • Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may
decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
- • Develop new features and services (for example, we may decide to build a new interests-based feature further
to requests received from users).
7) To prevent, detect and fight fraud or other illegal or unauthorized activities
- • Address ongoing or alleged misbehavior on and off-platform
- • Perform data analysis to better understand and design countermeasures against these activities
- • Retain data related to fraudulent activities to prevent against recurrences
8) To ensure legal compliance
- • Comply with legal requirements
- • Assist law enforcement
- • Enforce or exercise our rights, for example our Terms
9) To process your information as described above, we rely on the following legal base
- • Provide our service to you: Most of the time, the reason we process your information is to perform the
contract that you have with us.
- • Legitimate interests: We may use your information where we have legitimate interests to do so.
- • Consent: From time to time, we may ask for your consent to use your information for certain specific reasons.
You may withdraw your consent at any time by contacting us at the email provided at the end of this Privacy
5. HOW WE SHARE INFORMATION
Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course,
with other users. We also share some users’ information with service providers and partners who assist us in
operating the services, in some cases, legal authorities. Read on for more details about how your information is
shared with others.
1) With other users
- • You share information with other users when you voluntarily disclose information on the service (including
your public profile). Please be careful with your information and make sure that the content you share is stuff
that you’re comfortable being publically viewable since neither you nor we can control what others do with your
information once you share it.
- • If you choose to limit the audience for all or part of your profile or for certain content or information
about you, then it will be visible according to your settings.
2) With our service providers and partners
- • We use third parties to help us operate and improve our services. These third parties assist us with various
tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment
processing and security operations.
- • We may also share information with partners who distribute and assist us in advertising our services. For
instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
- • We follow a strict vetting process prior to engaging any service provider or working with any partner. All of
our service providers and partners must agree to strict confidentiality obligations.
3) With other Ufoto businesses
websites and apps such as Sweet Selfie, Sweet Snap, Candy Selfie and so on.
- • We share your information with other Ufoto businesses for them to assist us in processing your information,
as service providers, upon our instructions and on our behalf. Assistance provided by otherUfoto businesses may
include technical processing operations, such as data hosting and maintenance, customer care, marketing and
targeted advertising, finance and accounting assistance, better understanding how our service is used and users’
behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud,
infringement and other wrongdoings.
- • We may also share information with other Ufoto businesses for legitimate business purposes such as corporate
audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share user
information with other Ufoto businesses to remove users who violate our terms of service, or have been reported
for criminal activity and/or bad behavior. In some instances, we may remove that user from all platforms.
4) For corporate transactions
- • We may transfer your information if we are involved, whether in whole or in part, in a merger, sale,
acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or
5) When required by law
- • We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court
order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to
assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the
safety of any person.z
6) To enforce legal rights
- • We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened
lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other
interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other
action regarding illegal activity, suspected fraud or other wrongdoing.
7) With your consent or at your request
- • We may ask for your consent to share your information with third parties. In any such case, we will make it
clear why we want to share the information.
- • We may use and share non-personal information (meaning information that, by itself, does not identify who you
are such as device information, general demographics, general behavioral data, geolocation in de-identified form),
as well as personal information in hashed, non-human readable form, under any of the above circumstances.
- • We may also share this information with other Ufoto businesses and third parties (notably advertisers) to
develop and deliver targeted advertising on our services and on websites or applications of third parties, and to
analyze and report on advertising you see. We may combine this information with additional non-personal
information or personal information in hashed, non-human readable form collected from other sources.
6. CROSS-BORDER DATA TRANSFERS
Sharing of information laid out in Section 4 sometimes involves cross-border data transfers, for instance to the
United States of America and other jurisdictions. As an example, where the service allows for users to be located in
the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA.
7. YOUR RIGHTS
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active)
processing of your personal data; and to obtain the personal data you provide to us for a contract or with your
consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we
don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for
These rights may be limited, for example if fulfilling your request would reveal personal data about another
person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate
interests in keeping.
To exercise any of these rights, you can get in touch with us - or our data protection officer - using the details
set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority
where you live, work or where you believe a breach may have occurred.
8. HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal
information. As with all technology companies, although we take steps to secure your information, we do not promise,
and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information
collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of
security. If you believe that your account or information is no longer secure, please notify us immediately.
9. HOW LONG WE RETAIN YOUR INFORMATION
Where we process registration data, we do this for as long as you are an active user of our sites and for 12
months after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us
to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the
fact that you have asked us not to send you direct marketing or to process your data so that we can respect your
request in future.
Where we process personal data in connection with performing a contract, we keep the transactional data for six
years from your last interaction with us (or such longer period as may be required by law).
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above
guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical
10. CHILDREN’S PRIVACY
If you are a minor, you shall use our services with obtaining prior consent of your parent or legal guardian
(collectively, "guardian"). We recommend that the guardians of minors shall read this Policy carefully, and we also
recommend minors to obtain guardians’ prior consent and guidance before submitting personal information in your use
of our services.
Ufoto respects the privacy of children under the terms of COPPA. We do not knowingly collect or solicit any
information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service
and its content are not directed at children under the age of 13. In the event that we learn that we have collected
personal information from a child under age 13 without parental consent, we will delete that information as quickly
as possible. If you believe that we might have any information from or about a child under 13, please contact us via
you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued
By using our services, you agree that we may collect, use and share your Information in accordance with this
12. HOW TO CONTACT US
Third Part Policy check list：