Safety & Privacy

OUR COMMITMENT TO YOU:

At Spooner, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

1. Data controller

Spooner is extremely concerned about the protection of your personal data and respect for your privacy. The purpose of this privacy policy is to inform you on the way we process the personal data you share with us and that we collect when you use the Application and Services. Please read this document carefully to better understand how we process your personal data, and to know your rights.

This Privacy Policy applies to all Services published by Spooner that you use (with the exception of services supplied and operated by third parties, in which case, their privacy policy will apply).

2. INFORMATION WE COLLECT

Spooner collects and processes personal data on you when you use the Spooner application or when you communicate with Spooner. It may be information you share with us directly, or data we collect automatically.

To make sure our privacy policy is clear, we are providing below an overview of the personal data Spooner collects and processes. Information is given below for each type of data collected.

Mandatory data

Identification data
Depending on how you signed up, email address and/or telephone number
Data relating to your activity on the application
Technical data of the cell phone or device
Your city (if you refuse the geolocation feature)

Data required for certain purposes

Data relating to taking part in games and competitions, to your experience and your satisfaction
Geographical position or at least your city
Crossing points with other Members
Search preferences - people whom you would like to cross paths with (age and gender)
In-app messages and in-app voice messages sent and received
Data on Video Calls (the contents of such Calls are not collected)
Data relating to reports made and requests sent to the Spooner customer service

Optional data

Professional career and education
Interests, lifestyle, Member Characteristics
Depending on how you signed up, email address and/or telephone number
Description

2.1 Data you share directly

When you use our Services, you share information with us, some of which may be used to identify you. When you communicate this information, you accept that some of the data will be visible to the other Members of the Application, and therefore made public on the Application. In an effort to help you identify this information easily, it is signaled as ‘public’ below. Spooner cannot be held liable for data published on its platform and disclosed by a Member. However, information not marked as Public will not be visible or accessible by other Members; such information is signaled as ‘private’ below.

Spooner collects and processes data relating to your registration and data relating to your interactions with Spooner.

2.1.1. Registration data

Information required for registering

This is the basic data required for you to register and access our Services.

This data is collected by Spooner using different methods depending on the type of registration you choose.

If you choose to register using your Facebook, Apple or Google account, your data will be collected from the relevant platform in an effort to reduce formalism. By selecting “Log in with Facebook/Apple/Google,” you agree to having these platforms provide us with such data.

Depending on how you registered, some data must be collected in order to provide our Services. If such data is not obtained, Spooner will not be able to provide you with its Services via the Application, and you will not be able to create an Account. In all cases, your first name (public), age (public), birthdate (private), gender, and at least one Profile Photo (public) are required to register with the Application. Subsequently, you may add or remove Profile Photos at any time, providing you have added at least one Profile Photo containing a person’s face. As stated in paragraph 1, “Definitions,” the first Profile Photo should be a photo of a person’s face, otherwise one of your photos of your face will automatically be put in first position.

If you register using your phone number, you must provide said phone number in order to register.
When you register via Facebook, we must collect your first name and your age. You may also allow Facebook to provide Spooner with your last name, birthdate, gender, email address, and to transfer your Profile Photos from Facebook.
When you register via Apple or Google, we must collect your first name and email address. Said platforms may also provide Spooner with your last name.

In addition, if you refuse the geolocation feature when registering, and thereby the possibility for Spooner to collect your location data to suggest Member profiles with whom you have crossed paths, you must provide the name of your city. This information will enable Spooner to suggest Member profiles near you.

Optional information to complete your profile

You may add additional information to improve your profile. This information is optional, shared at your own discretion, and is your sole responsibility. You can add this information directly to your profile on the Application and/or via Facebook Connect by syncing your Account with Facebook. This data is as follows:

professional career and education (public): profession or studies;
interests and habits (public): personal preferences, leisure activities, musical preferences, lifestyle, Member Characteristics;
height (public);
profile description (public): if you would like to, you can share additional information about you in the space provided for this purpose. This information will be visible to Spooner Members. Moreover, if you so wish, you can also answer the questions on your lifestyle (personality traits, sports, travel, type of meeting expected, etc.).

Your description is a free text area, Spooner does not encourage Members to share data that can be perceived as sensitive with other Members, or with Spooner through the Application. More specifically, it includes information on race or ethnicity, political opinions, religious or philosophical beliefs or affiliation with a union, along with information on health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on his/her profile regardless, it is deemed to have been “clearly made public” by the Member who shared it, according to the GDPR.

2.1.2. Data relating to interactions with Spooner:

When you contact our customer or support services, report an issue with our services, ask for help, exercise your personal data rights, or participate in promotional activities, games, competitions or surveys, when you share your experience of our services, give testimonies, or answer one of our questionnaires, Spooner will collect, depending on the case, the following personal data:

Data relating to reports and requests sent to the Spooner customer service (private): Date and time of the report, nature and reason for the report, data relating to the reported user. Furthermore, proof of identity may be requested as part of the exercise of your rights over your personal data, and for safety/confidentiality reasons.

This data will be collected by Spooner when you ask for help from our customer service, exercise your rights over your personal data, report a problem or another user. Such information is required to handle reports or answer your requests. This information will also be handled if a report is made about you. In fact, Spooner has a legal obligation to collect reports from its Members brought to its knowledge regarding contents or behavior likely to infringe our Terms of Service.

Data relating to taking part in games and competitions, to your experience and satisfaction (private): participation, responses, satisfaction level, suggestions, experience.

Such data is collected by Spooner when you take part in our games and competitions, answer our surveys and satisfaction questionnaires, share your experiences. This data is mandatory if you wish to take part in the games and competitions organized by Spooner. Without this data, Spooner may not register you for games or competitions. However, data on your experiences and satisfaction is optional.

2.2 Data we collect automatically

When you use our services and features, we collect information on your activities on the Application:

Activity data (private) (registration date, login dates, on or offline status, interactions with Members and third-party accounts, number of transactions, notifications received, notification preferences, etc.)

When you access our Services and use the Application and its features, information on the way you use them is collected and processed. Most of the information collected by Spooner is necessary to the provision of its Services. Without this data Spooner cannot supply the Services linked to the Spooner application.

More specifically, this includes your registration date, login dates, on or offline status, the type and number of interactions with other Members (such as FlashNotes, Hellos, Likes, crossings, and Crushes), with the third-party accounts connected to your Account (such as Spotify, Instagram), or the number of transactions made (purchases of Hellos, FlashNotes, or subscriptions), notifications received and notification preferences.

Geographical positions and Crossing points with other Members (public)

The Application’s main value and purpose is to allow Members to find other Members they have or may have crossed paths. Your Geographical position is collected with your express consent only. In fact, you will be asked to authorize the collection and processing of your location data to allow Spooner to identify your crossing points with other Members who have agreed to be geolocated.
your crossing points with other Members who have agreed to be geolocated.
Unless you have chosen stricter settings on your device, Spooner will collect your Geographical position regularly.
When the Geographical positions of two Members are within a certain radius, Spooner pinpoints a Crossing point.

Your Crossing points will be displayed on your profile, but Members with whom you cross paths can never see your exact location. Each Member sees his/her location when the Crossing point was registered in a radius defined by Spooner. They cannot see the other Member’s location.

During your registration, if you do not provide your consent for geolocation, you must provide the name of your city. This information will enable Spooner to suggest profiles of Members near you.

These Crossing points can be displayed as a news feed or on a Map (Mapping).

You may, at any time, withdraw your consent by disabling geolocation on your smartphone. If you choose to do so, your news feed will no longer be updated, and you will not be able to see who you have crossed paths with after disabling the geolocation option. When you have no more profiles in your newsfeed, we will ask you the name of your city in order to suggest new Member profiles near you.

You can also ask that your profile, and therefore your crossing points, are no longer displayed on the Map (Mapping). In this case, you will only appear in the news feed of other Members. Equally, you will no longer be able to see the profiles of Members you have crossed paths with on the Map (Mapping); you will only see these profiles on your news feed. For this, go to the application and click on “My preferences” then go to the bottom of your screen and disable the option “Share my crossing cluster”.

Text messages and voice messages sent and received (private)

Messages are sent and stored on Spooner servers, to provide the Service to allow Members with a Crush to have a conversation or when a Member uses the FlashNote function. Messages and voice messages are strictly private and only implicate the Members involved. Spooner authorized managers do not exercise any rights to view these conversations. These Messages are not transmitted or communicated to third parties except in cases of judicial requests, and/or in compliance with the applicable legislative or regulatory provisions. Moreover, Messages are strictly private and are not accessible to other Members who are not involved in the conversation, nor to any third party.

Information relating to Video Calls (start and end time/date of calls, etc.) (private)

If you wish to make a Video Call using Spooner, your telephone’s technical data is required in order to establish communication between the two Members. Spooner will collect the start and end time/date of Video Calls, but not their content. Such Video Calls are instant.

Search preferences - people whom you would like to cross paths with (age and gender) (private)

The Application lets you set preferences by age, gender, and the Member Characteristics they have provided. You can change these settings in the Application and specify the age range and Member Characteristics, and, after agreeing to Spooner collecting and processing your data, the gender of people you are looking for, so you can be matched exclusively with profiles you crossed paths with and who meet your search criteria. You will then only see the Members you have crossed paths with and who share your search preferences on your news feed.

Technical data of the cell phone or device (IP, mobile ID, application version, telephone version and model advertisement ID, etc.) (private)

We collect information from the devices and equipment you use to access our Services, including server logs, which may contain information such as IP addresses, version of the application, device version and model, language used, operating system, application crashes, and advertisement ID. Data may be collected with cookies or other tracking tools: to learn more about this, please refer to our document on the Use of Cookies.

Transaction Data: Spooner does not collect or process any banking data. Apple’s App Store and Google’s Play Store have opted to refrain from sending certain types data to mobile applications, which includes any banking and financial information. This data is collected and processed solely by the above platforms, and Spooner does not have the option of changing this payment method. The only information exchanged between Spooner and Apple’s App Store or Google’s Play Store is technical data that does not allow us to identify you (for example, a transaction number), and is used to validate transactions. Spooner will therefore retain a history of your purchases and subscriptions but will not store any information relating to the payment methods you use.

3. HOW DO WE USE YOUR DATA?

3.1. Supply of services and features according to our terms of service

Creation and management of your Account as a Member:

Creation of your profile.
Registration, deregistration, deactivation of your Member profile.
Management of parameters and preferences.
Management of subscriptions.
Management of access to the Services proposed by Spooner.

Managing and storing messages exchanged between Members (Messages, FlashNotes, Hellos, Crushes, Likes).

Managing Video Calls between Members

Managing subscriptions and paid Services purchased(Hellos, FlashNotes, call credit, etc.)

Sending information messages relating to the Services or your interactions with other Members (notifications).

3.2. Suggesting profiles you have crossed paths or may cross paths with

Geolocation to suggest profiles of Members you have crossed paths or may cross paths with.

Additional information

The aim of the Application is to help you find other Members whose paths you have crossed or may cross. In fact, it allows you to identify your crossing points with other Members who have agreed to be geolocated. These crossing points allow Spooner to show you profiles of Members you have crossed paths or may cross paths with and who meet your search criteria.

Based on your activity in the Application, your position and the information on your profile, your profile may be suggested to other Members. We can also recommend, via your Shortlist, other Members who may interest you, with whom you have crossed paths, or with whom you could cross paths, and, inversely, recommend your Profile to other Members. Your profile is also suggested when you use the Boost feature as defined in paragraph 1.
Recommend your Profile via email to other Members with whom you have crossed paths or with whom you could cross paths.

3.3. Suggesting relevant offers and contents (marketing and advertisements)

Sending marketing or advertisement messages or contents:

Send the Spooner editorial newsletter by email. We will stop sending the newsletter to Members who have not opened it in over a year.
Send a newsletter suggesting Profile recommendation that can be viewed on the Application (your Shortlist).
Distribute marketing contents and advertisements related to Spooner offers and services on the application and by emails.
Provide Members with offers and/or promotions on Spooner services.

Conducting marketing operations and advertising outside of the application: we conduct marketing operations and advertising outside of the Spooner application outside of third-party sites, social networks and third-party applications. If you are already a Member of the Application, we may share you email address and telephone number with such entities to exclude you from our Marketing campaigns. This information is provided for “hashing” purposes. This can also help Spooner disseminate its campaigns to profiles similar to yours, who may be interested in our Services. The existence of your profile will never be disclosed to these similar profiles. The social networks which may receive your data for this purpose appear in the list of our service providers, available here.

Display personalized advertisements on the Spooner Application with regard to third-party products and services to ensure they are relevant to the Member. These advertisements are personalized based only on your age group, gender and the country and/or city where you live. Your personal preferences will not be analyzed in disseminating such advertising. Personalized advertising also includes the restricting of identical advertisements. As a result, when a Member consents to it, repeated or irrelevant advertisements are limited and the Member will see more diverse content.

Disseminating on the Spooner application non-personalized advertisements (based solely on your country), on the products and services of partners and advertisements relating to the products and services of Spooner.

3.4. Improving and optimizing our services and our knowledge of how you use them

Improvement and optimization of the services of Spooner, of the knowledge of its Members and the manner of using the Services:

Statistical studies.
Satisfaction survey.
Analyses of the use of the Application and Services by Members.
Understanding how our Application and its features are used
Improving our Application, offers and features
Understanding your needs

Provide Members with advice on which Profile Photos to publish by analyzing all Members’ profiles, so Members can, if they wish to do so, optimize the way their profile is presented.

3.5. Guaranteeing the security of your personal data

Detecting or preventing breaches of the security of the Services by identifying and analyzing fraudulent behavior.

3.6. Preventing and combating illegal or unauthorized activities (breaches of the terms of service), ensuring the trust of Members and complying with legal requirements

Analysing and processing reports of fraudulent/undesirable behavior.
Managing undesirable behavior and warning, suspending, blocking or deleting the Member’s Account.
Managing requests to exercise Members’ rights over their data.
Detecting or preventing fraudulent activities or activities which breach our Terms of Service:
- Automated analysis of profile data, application activity to detect fake profiles, fraudulent behavior or behavior that breaches the Terms of Service.
Guarantee the quality of profiles:
- Automated analysis of Members’ Profile Photos in order to detect faces, and, as much as possible, exclude fake profiles from the Application, combat fraudulent behavior and guarantee Member identification. You will not be able to create an account if your face cannot be detected in one of your Profile Photos upon registering. If you are prevented from registering even though your Profile Photo does show your face, you may contact us at any time.
Profile certification (as defined in paragraph 1): in order to certify the profile of a member, Spooner must, having obtained the Member’s consent, collect the his or her biometric data using a video of his or her face, and compare this data with the Member’s Profile Photos. If the faces correspond, a “Certified Profile” badge will be granted. The biometric data are immediately deleted after the comparison. However, the video will be stored in order to reverify the Member’s profile should he or she add or delete other photos. In this case, the biometric data will be collected once again from the same video, then deleted again after comparison with the Member’s new photos.

3.7. Providing Members with help and technical support

Responding to the requests for support submitting by Members using the Application

4. COOKIES AND TRACKING TOOLS

Cookies may be used on our showcase website for technical, advertising reasons or for measuring audiences. In the Application, cookies and tracking tools may be used for technical reasons and for measuring audiences.

To learn more, read our document on the Use of Cookies on our website.

5. HOW DATA IS SHARED

Only certain Spooner employees from customer services and authorized managers process Members’ personal data for the purposes described above. These employees and authorized managers only have access to the data necessary to perform their duties.

Authenticated and reliable service providers and partners, who may access and/or process Members’ personal data, in compliance with the Privacy Policy, and ensuring the security and privacy of the Members’ personal data. These service providers help us operate and improve our Services, including

our sub-contractors in charge of data infrastructure and hosting
suppliers of the analysis software we use
technical sub-contractors for using the Application and/or ensuring that the Application functions properly
our customer service to provide Members with the support they need and manage reports;
our Marketing partners to provide Spooner Members and non-Members with relevant messages, offers and content.

As part of marketing and advertising operations outside the Application intended for non-Members, your data may be provided to partner social networks in order to exclude you from our campaigns, unless you oppose that.

In addition, at the request of state bodies, in particular the judicial authorities, and in order to comply with any judicial or legal request, Spooner may transmit the personal data of its Members.

Lastly, we may be required to share your data for the purposes of corporate operations, which include, but are not limited to, a restructuring, a change in control of the company, a merger, an acquisition, a transfer, or a termination of the company.

6. HOW LONG WILL WE KEEP YOUR DATA?

Spooner has introduced a process for automatically deleting your account and your personal data with regard to the storage time limits defined below. When certain data must be stored for statistical uses beyond these storage time limits, this data is anonymized irreversibly to ensure you can no longer be identified.

Spooner will store the Member’s data for as long as required in order for the Member to use his/her Account, namely:

For the length of the Member’s registration, plus one year After one year of inactivity on an Account, the Account will be deleted and the Member’s data will be retained for another year, before being permanently destroyed or irreversibly anonymized. An account is considered inactive when the Application of the Member has not established contact with Spooner servers (including due to deactivation of the geolocation process); and the Member has not used the Application. In any event, the Account of a Premium Member is not considered inactive. Furthermore, please note that in accordance with its status as a hosting provider, Spooner has a legal obligation to retain some of its Members’ personal data for a period of one year based on Article 6, II of the French Trust in the Digital Economy Act (Loi pour la Confiance dans l’Économie Numérique) of 21 June 2004.
When a Member is banned, his/her Account becomes inactive. Information from this Account is retained in an active database for one year, in order cross check it with information provided with new registrations to the Application, in order to prevent, to the extent possible, banned users from registering again. Subsequently, the personal data is archived for one more year, after which it is deleted permanently or irreversibly anonymized.
When the Member deletes his/her Account or requests its deletion from Customer Service, it will be deleted from the Application. However, the Member’s data will be kept in a separate archive for one year before being permanently destroyed or irreversibly anonymized, in order to enable Spooner to comply with its obligation to keep it as host.
Some of the Member’s data, such as email address and telephone number, will be retained for prospecting or Marketing purposes (see Article 4.3) or to be analyzed in order to improve and optimize our service (see Article 4.4) for one year after an Account has been inactive for one year. If a Member deletes his/her Account, this data will not be used for prospecting or marketing purposes.

With regard to your Geographical Positions and Crossing Points, shorter storage times apply:
- Your Geographical Positions are stored for one month from their collection in order to determine your Crossing Points with other Members;
- Your Crossing Points are stored for six months from their collection in order to display the Profiles of Members you have crossed on the Application.
Spooner undertakes to make every effort and to invest all means at its disposal to guarantee that the stored data is kept as secure as possible. However, it is the Member’s responsibility to take appropriate measures to protect his/her data.

7. PERSONAL DATA OF MINORS

Spooner shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be an adult, the parents of the minor in question should inform Spooner of this fact by sending an e-mail to one of the contacts mentioned in Article 11 “Contact”, requesting the data to be deleted. Spooner commits to deleting all data on the minor in question as soon as possible.

8. DATA RETENTION AND DELETION.

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law. When you delete your Account, or it is deactivated by us, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted or wrongfully deactivated. After 28 days, we begin the process of deleting your personal information from our systems, unless: we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes); we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block); there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or The information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account). Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies. Thanks for reading, we hope we didn’t drone on for too long!

9. CONTACT

If you have any questions regarding this privacy policy, or any other request concerning your personal data, you can contact us:

By sending an e-mail to our contact e-mail address info@spooner.com.