Last Updated: 1st January 2024
This Privacy Policy is designed to help you understand how SOMO (BVI) Limited (Reg: 2141544) of Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands (collectively with any subsidiaries, called “SOMO,” “we,” “us,” and “our”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.
1. SCOPE
This Privacy Policy applies to personal information processed by us, through our websites, mobile applications, games that we operate, and any other services or interfaces owned or controlled by SOMO that link to this Privacy Policy (each a “Service” and together, the “Services”).
2. CHANGES TO OUR PRIVACY POLICY
We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. We encourage you to periodically review this privacy statement to learn how SOMO is protecting your information. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
3. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect personal information that you provide to us, personal information we obtain automatically when you use our Services, and personal information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
Your Communications with Us. We may collect personal information, such as email address, phone number or mailing address when you request information about our Services, apply for a job or otherwise communicate with us.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services such as:
Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your browser or device information, location information (including approximate location derived from IP address). We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
Cookies and Other Technologies. We, as well as third parties that provide content or other functionality on our Services, may use cookies, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
Our use of Technologies is limited to that which is strictly necessary to allow you access to our Services and to make use of our functionality.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications.
C. Information Collected from Other Sources
Third-Party Sources. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
4. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and services, as described below.
If your personal information is subject to the General Data Protection Regulation or UK General Data Protection Regulation, our processing of your personal information will be under one of the following lawful bases:
A. Processing Necessary for Us to Provide Our Services
We process your personal information to perform our contract with you and provide you with our Services including by:
B. Administrative Purposes
We use your personal information for our legitimate interests, such as:
C. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information and for which you provide your consent.
D. Other Purposes
We also use your information for other purposes as permitted by applicable law.
De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, information about how you use the Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.
5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
Other Users of the Services and Parties You Transact With. Some of your personal information may be visible to other users of the Services (e.g., information featured on generally accessible parts of the contracts or on a user profile). In addition, to complete transfers via the Services, we will need to share some of your personal information with the party that you are transacting with.
Third Party Websites and Applications. You may choose to share personal information or interact with third-party websites and/or third-party applications, including, but not limited to, third-party electronic wallet extensions. Once your personal information has been shared with a third-party website or a third-party application, it will also be subject to such third party’s privacy policy. We encourage you to closely read each third-party website or third-party application privacy policy before sharing your personal information or otherwise interacting with them. Please note that we do not control, and we are not responsible for the third-party websites’ or the third-party applications’ processing of your personal information.
Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, customer service, and related services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
Affiliates. We may share your personal information with members of our corporate family.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, to the extent permitted by law.
6. YOUR PRIVACY CHOICES AND RIGHTS
The privacy choices you may have about your personal information are determined by applicable law and are described below.
Your Privacy Rights. In accordance with applicable law, you may have the right (subject to certain limitations) to:
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
7. INTERNATIONAL DATA TRANSFERS
All personal information processed by us may be transferred, processed, and stored anywhere in the world, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, we will use a valid data transfer mechanism to ensure that your personal information is transferred in accordance with this Privacy Policy and applicable data protection laws.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
8. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy only for as long as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
9. SECURITY OF PERSONAL INFORMATION
We employ appropriate technical and organizational measures designed to protect the security of all personal information we collect. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We will continue to evaluate these measures to ensure the security of the processing.
10. CHILDREN’S INFORMATION
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information without your consent, you may contact us as set forth in “Contact Us” below. If we learn that a child has provided us with personal information in violation of applicable law, we will promptly take steps to delete such information, unless we have a legal obligation to keep it.
11. THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
12. COMPLAINTS
If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as set forth in “Contact Us” below.
If you are located in the European Economic Area or Switzerland you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
13. CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at [email protected].