1. EEA/UK/CH -DE
2. EUR/UK/CH-EN
3.US
EEA/UK/CH
Privacy Policy
Date of entry into force: 19 November 2023
Introduction:
This privacy policy (“Privacy Policy”) applies to the processing of personal data by the Soulside App in connection with the Soulside applications, websites, software and related services (the “Platform”) that link or refer to this Privacy Policy.
Data Controller: If you are located in the European Economic Area (“EEA”),
United Kingdom (UK) or Switzerland, Soulside GmbH is a German-based company responsible for processing your data in
connection with this privacy policy.
Information we collect
We collect your information in three ways: Information you provide, automatically
collected data and data from other sources. Further details are below
listed.
Data provided by you
● Profile information. We collect data that you provide when setting up a
account, such as your date of birth, your username, your
E-mail address and/or phone number and your password. You can
Add more information to your profile, such as a description or a
Profile photo.
● User Content. We collect the content you create or share through the Platform
published content, such as photos, videos, audio recordings,
Livestreams, comments, hashtags, feedback and reviews as well as the
associated metadata (e.g. when, where and by whom the content was created
Even if you are not a user, information about you may be
appear in content created or published by users on the platform.
We collect user content by pre-loading it to
Time of creation, import or upload, regardless
whether you store or upload this User Content, for example to upload music
based on the video. We also collect content (e.g.
text, images and videos) from your device’s clipboard when you
Copy and paste content to the platform or transfer content between the
Platform and a third-party platform.
● Direct messages. When you communicate with others via direct messages
communicate, we collect the content of the message and the associated
Metadata (e.g. the time at which the message was sent, received
and/or read, as well as the participants of the communication). We
also record messages that you send via our chat function or
receive when you communicate with merchants who sell you goods
sell via Soulside.
● Your contacts. When you synchronize your contacts, we access data
from your device’s phonebook such as names,
Telephone numbers and email addresses, and compare this data with the
users of the platform. If you share information with other users via your social
Add network contacts, we collect your public
Profile information and names and profiles of your social network contacts.
● Purchase information. When you make a purchase or payment on the or
through the platform, including the purchase of Soulside Coins
or goods through our shopping functions, we collect data for
Purchase or payment transaction, such as payment card information,
Billing, delivery and contact information and the
purchased items.
● Surveys, research and promotions. We collect from you
provided data when you register to participate in a survey, a
Research, a promotion, a competition, a marketing campaign
or an event organized or sponsored by us
decide.
● When you contact us. When you contact us,
we collect the data you send to us, such as identity or
Proof of age, feedback or inquiries regarding your use of the platform
or information about possible violations of our
Terms of Use (our “Terms of Use”),
Community Guidelines (our “Guidelines”) or other terms.
● Information from forms and functions you use.
We collect the information you provide when you
Fill out the form on the platform. You can use Soulside Registration Forms
automatically filled in with your account information, such as your
addresses or payment information.
Automatically collected data
● Technical data. We collect certain device and
Network connection data when you access the platform. These
Information includes your device model, operating system,
Keystroke patterns or rhythms, your IP address and your
System language. We also collect service-related, diagnostic and
Performance data, including crash reports and performance logs. We
automatically assign you a device ID and a user ID. If you
log in from multiple devices, we use data such as your
Device ID and your user ID to track your activities across devices
identify you so that we can provide you with a seamless login experience
and for security reasons.
● Usage information. We collect data about how you
use our platform, including data about the
content viewed, the duration and frequency of your use, how you interact with
contact other users, your search history and your preferences.
● Content features and characteristics. We recognize and collect
Features and characteristics of the video, image and audio recordings that are part of
of your User Content, e.g. by identifying objects and
Landscapes, the presence or position of a face or
other body parts within an image and the text of the
Words spoken in User Content. We do this, for example, for the
Moderation of content and provision of special effects (such as
video filters and avatars) and subtitles.
● Inferred data. We infer from the data we hold about you
based on your characteristics (e.g. age group and gender) and
interests. We use these conclusions, for example, to improve our
To keep the platform secure, to moderate content and, where permitted, to
Personalized advertising based on your interests
to provide.
● Cookies. We use cookies and similar tracking technologies for
the operation and provision of our services. We use cookies
for example, to save your language settings, to
ensure that you do not see the same video more than once, and
for security reasons. We also use these technologies for
Marketing purposes. Where required by law, we will collect your
Consent to the use of cookies.
Data from other sources
● Advertising, measurement and data partners. Advertisers, measurement services and other
Partners share information about you and your behavior outside of the
Platform, such as your activities on other websites and apps or in
Business, including the products or services you purchase online
or personally purchased. These partners also share information with us such as
e.g. mobile identifiers for advertising, hashed email addresses and
Cookie identifiers
● Merchants, payment and transaction service providers. We receive
Information about you from merchants and payment and
Transaction services, such as details of payment confirmations and
Information about the delivery of products that you order through our
have purchased shopping features.
How we use your personal data
use
We use your information to operate, provide,
to further develop and improve, among other things for the following purposes.
● Providing and managing our services, e.g. to provide you with the opportunity
to create, share and consume content and to communicate with others
to interact with users and their content.
● Providing our shopping function and facilitating purchases and
the supply of products, goods and services, including
Sharing your information with merchants, payment and
Transaction services and other service providers to process your orders
edit.
● Personalization and customization of certain features and content on the
Platform, such as providing your “For You” feed.
● Enforce our terms of use, policies and other applicable laws
applicable regulations. We review User Content and other
Information through a combination of technological tools
(including automated solutions) and human moderation to
to protect the safety and well-being of our community.
● Providing certain interactive features, such as the ability to
Use your content in other users’ videos and show other users
Suggest your account to connect you with other users
bring.
● Providing and improving our advertising services, including
Displaying advertisements (including personalized ads, where
permissible) and measuring and understanding the effectiveness of
ads and other content.
● Maintaining and improving the security and stability of our
Services by identifying and correcting technical or
security-related problems (e.g. technical bugs, spam accounts,
Detecting abuse, fraud and illegal activities).
● Review, improvement and further development of the platform, including through
Monitoring interactions and usage across your devices,
by analyzing the use of the platform by users and by
Training, testing and improving our technology, such as
our machine learning models and algorithms.
● Promotion of the platform or third party services through
Marketing communications, competitions or promotions.
● Fulfill our legal obligations or to comply with
Tasks that are in the public interest or to protect the
essential interests of our users and other persons.
How we use your personal data
pass along
Service provider
We engage service providers to help us deliver our services,
support and develop them and understand how they are used. They
offer the following services, among others:
● Cloud hosting and content delivery,
● Customer service and technical support
● Moderation of content
● Marketing
● Analytics and online payments
We share the information you provide, automatically collected information and
Data from other sources to these service providers to the extent necessary for them to provide their services.
partner
third-party platforms and partners. We share limited information,
to which the data, technical data and information provided by you
about the use, with third-party platforms and partners whose platform
or services are integrated into the platform. We do this to provide you with a seamless
experience and enable you to share your content on other platforms
and/or to enable third-party platforms and partners to better authenticate users. For example, if you decide:
● log in with your account details from a third-party platform (e.g. Facebook or
Google) to register or log in to the platform, we will
pass on certain technical data to enable this;
● User Content that you publish on the Platform on other
social media platforms, we will share your User Content and
share related data.
Advertising partners. We provide advertisers with aggregated data about the
performance of their ads and other content on the platform to
to help them measure their effectiveness. We create these
aggregated data using the data you provide,
automatically collected data and data from other sources. We share your data
directly to advertisers if you give us your permission to do so.
Measurement and data partners. We share the data you provide, your
technical data and information about usage to third parties,
that help us measure advertising on our platform and improve our
To help advertisers determine the effectiveness of their advertising.
Merchants, payment and transaction service providers and others
Service providers. If you use the shopping functions on our platform to purchase a
make a purchase, we pass purchase information about the transaction to the merchant, provider
payment and transaction services and other service providers. We forward
for example, information about the ordered item, contact details and
delivery information so that your order can be processed. We
may also provide these parties with certain technical information about your device or
Disclose connection type to ensure transaction security.
Other
We share your information in some other scenarios as follows:
users and the public. Depending on your privacy settings, your
Information, including your profile information, user content and
Information about usage, visible to other users and the public
For example, if you have a public account and visibility
of your contributions have not been individually restricted, your profile information
and User Content from anyone on the Platform or outside the Platform
viewed or shared, regardless of whether the person concerned is a
Soulside account or not. Depending on your privacy settings, your profile information and User Content may also appear on search engines, content aggregators, and news sites.
Users of our analytics services. We provide aggregated statistics and insights
to help people and businesses understand how the
Platform. For example, creators and advertisers can receive information about the number of views, likes, comments and shares on their videos, as well as demographic information about their followers and viewers of their videos. We create this aggregated data using the
Data provided to you and data collected automatically.
Corporate transactions. Your data may be used in connection with a
Corporate transaction such as a merger, sale of
assets or shares, a restructuring, financing, change of control or acquisition of all or part of our business. Legal obligations and rights. We may rely on the information set out in “Our
information described in the “Information Collected” section, store it and
Law enforcement agencies, government agencies, researchers, copyright owners or other third parties if we have a good faith belief that doing so is necessary to:
● comply with applicable laws and legal processes or regulatory
Requests in accordance with internationally recognized standards
to comply;
● the rights, property and safety of our users, the owners of
copyright and other persons, including the
Protection of human life or the prevention of imminent physical
Damage. For example, in an emergency, we may store data (such as your
IP address) to law enforcement authorities if it is necessary
endangering the life or safety of a person;
● possible violations of our terms of use, policies or
other applicable regulations, guidelines or standards
investigate and enforce; or
● misleading activities, copyright infringement or other illegal
to detect, investigate, prevent or combat activities.
For more information about how we handle requests from law enforcement and public authorities, please see our Law Enforcement Data Request Policy. Our legal bases and how we process your personal data
We only use your data if we have a “legal basis” to do so.
Depending on why we use your data (in other words, depending on the “purpose” of our processing), we use different legal bases.
Legal bases include contractual necessity, legitimate interests
(ours, yours or that of another party), consent, the performance of a
legal obligation to perform a task in the public interest
and the protection of essential interests.
Here we explain the legal basis on which we rely when processing your
This section also describes why we use your data
use, how this data is processed, what data categories are involved
and what rights are associated with it (which always includes the right to
information about your data). For more information about how to exercise your rights
For more information about how you can exercise your right to object to such processing, please see the “Your Rights and Choices” section in the
Privacy Policy.
Contractual necessity
For all persons who are legally able to
To enter into an enforceable contract, we will use the information you provide
Data, automatically collected data and data from other sources, if this is necessary for
Fulfillment of the contract you entered into when registering, accessing or
use of the platform (our Terms of Use).
means that we use your data to:
● Provide you with the platform. We use your data to
To enable you to access and use the Platform,
including the ability to create and consume content with
interact with others, use social features and offer you products
and services you purchase. We also personalize
certain functions and content on the platform, e.g. through the
Providing your “For You” feed, which shows you videos that we
believe that they would interest you and by suggesting
accounts.
● Product orders and deliveries. We use your data to
To process orders, e.g. to purchase and deliver
products and to send you messages about your orders
This includes sharing purchase information with retailers,
Payment and transaction service providers and other service providers
● Our terms of use, policies or regulations
We use your data to enforce our
Enforce terms of use, policies and guidelines
(including automated solutions and human moderation). This
may impose an age restriction on adult content, the retention
our For You Feed eligibility standards, the removal of content
or suspending your account if we determine that you
violate our terms of use or policies.
● To manage our services. We use the data we have
also to administer our services, for example to communicate with you regarding the
Service, to contact you regarding your transactions made through the Platform
To keep you informed about your purchases or to support your
To process enquiries, claims or complaints (including
Reporting a problem or requesting a copy of your data).
Your rights: Whenever we process your data because it is necessary for the contract,
we have concluded with you, you have the right to request the
to have the data made available to you transferred.
Legitimate interests
We use your data if this is necessary to protect legitimate interests
is necessary – regardless of whether it concerns us, you or a third party –
provided that these interests are not overridden by your interests or fundamental rights
and freedoms. We use your data to:
To enable the use of your videos in interactive features.
● Our interactive features like Duet and Stitch allow others
Users to embed your videos in their own videos (if you allow this in your
Allow settings).
● Legitimate interest we rely on: Providing users with tools to
that encourage creativity, collaboration and enjoyment
and give users the opportunity to reach new target groups
to reach.
● Data used: Data provided by you and automatically collected
Data.
Suggest your account to other users.
● We may suggest your account to other users, for example if a user
synchronizes his contacts with the platform.
● Legitimate interest we rely on: To provide users with
enable us to quickly and efficiently find other users on our platform
find and get in touch with them.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
Providing non-personalized advertising to all users.
● We show non-personalized advertising to all users, including those who
have opted out of personalized advertising.
● Legitimate interest we rely on: We do not show
personalized advertising so that we can continue to offer the platform free of charge
We process limited categories of your data to
ensure that our advertising service is useful to our advertisers
(e.g. to show users in a particular country or users who have the same
speak language, display advertising).
● Data used: Data provided by you and automatically collected
Data.
To provide measurement and analysis services.
● We help creators and advertisers improve the effectiveness and
Distribution of advertisements and other content published on the platform
displayed.
● Legitimate interest we rely on: To ensure that creators and
Advertisers can see and understand how their ads or content
perform and which audience views their ads or content
or interact with them. This enables them to make informed decisions (e.g.
B. about what kind of advertising campaigns they want to run, which
target group they want to reach and what content is best for users
This helps ensure that the advertising and other content we
show users, remain relevant and entertaining and that the platform
remains free for all users.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
To ensure the safety and well-being of our community.
● We use your data to ensure the safety and well-being of our
Community, including the verification of
User Content (and, where permitted by applicable law,
direct messages and associated metadata) for violations of our
Terms of Use, Policies and other terms. We value
your age group and may ask for additional
Information to confirm your age.
● Legitimate interest we rely on: To ensure the security
our community, to ensure compliance with our policies
and uncover misuse of the platform.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
To ensure the security and stability of the platform.
● We use your data to ensure the stability and security of the platform
including the identification and resolution of technical
or security issues (such as technical bugs, spam accounts and
detecting abuse, fraud and illegal activities).
● Legitimate interest on which we rely: To ensure the stability and
To ensure the security of the platform and to ensure that it
is constantly available and functional.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
To review, improve, promote and
to develop further.
● We use the data available to us to understand how
the platform is used by users and to use the platform
to further develop, test and improve, including the
Developing and improving our technology, such as our
machine learning models and algorithms. We use these
Information also about the platform, popular topics and new trends
to better understand and promote.
● Legitimate interest we rely on: improvement,
Promote and develop the platform in a well-founded manner.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
To enable communication for marketing purposes.
● We may send you direct marketing messages about features of our
Services and third-party services that we believe are
you are interested in. We may also send you promotions, competitions,
marketing campaigns or events. We will collect your
consent to send you such messages, provided that this
is required by law.
● Legitimate interest we rely on: To operate the Platform or
To promote third party products and services.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
Your rights: Whenever we process your data based on legitimate interests
use, you can object to this and request the restriction of the use
demand.
If you are under the age of majority (in most relevant countries under
18 years) and have only limited ability to enter into an enforceable contract
and we do not process your data due to contractual requirements
we rely on legitimate interests and use the
data we collect to:
To provide you with the platform
● We use your data to provide you with access to the platform and its
use, including the ability to create content,
to share and consume, to interact with others, to use functions
and offer you products and services that you
acquire.
● Legitimate interest we rely on: provision,
Support and maintenance of products and features that enable users
without the possibility of an enforceable contract with us, with
To communicate, discover and engage with content
or to express themselves. We also rely on the legitimate
Interest of our users to use the platform in a simple and intuitive way
to be able to use.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
Personalize features and content
● We also personalize certain content based on your data.
Features and content on the platform, e.g. by providing your
“For You” feed, which shows you videos we think you will
would be interested in and by suggesting accounts.
● Legitimate interest we rely on: provision,
Support and maintenance of products and features that enable users
without the possibility of an enforceable contract with us, with
content that matches their interests, to inform them
discover and engage with them. We also rely on the
legitimate interest of our users who do not have an enforceable contract with
us to access the platform and content,
that match their interests.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
Our terms of use, policies or regulations
to enforce.
● We use your information to implement our terms of use, policies and
principles (including automated solutions and
human moderation). This may include age restrictions on content for
Adults, maintaining our For You
Feed eligibility standards, removal of content or
suspension of your account if we determine that you have violated
violate our terms of use or policies.
● Legitimate interest we rely on: To keep the platform free from
harmful or inappropriate content in order to identify suspicious
Activities or violations of our Terms of Use, Policies
or principles and to ensure the safety of users
who cannot enter into an enforceable contract with us,
including preventing exploitation or other harm,
to which these people may be particularly exposed. This is also due to the
legitimate interest of our users who do not have an enforceable contract with us
and the public in general to avoid bad
experiences and to ensure the security, integrity and protection
to promote.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
To manage our services.
● – We use the data we have to manage the platform, e.g.
B. to communicate with users and to process requests, demands or
To respond to and process complaints (including notification
a problem or request a copy of your data).
● Legitimate interest we rely on: To provide our users who
cannot enter into an enforceable contract with us, meaningful
To provide information on service-related matters
and to handle your inquiries, claims and disputes.
● Data used: Data provided by you, automatically collected
Data and data from other sources.
Your rights: Whenever we process your data based on legitimate interests
use, you can object to this and request the restriction of the use
demand.
Your consent
We will obtain your consent to access or use your information for specific
purposes. If we do so, you can withdraw your consent at any time
via device permissions or in-app settings.
Personalized advertising.
● With your consent, we will show you personalized advertising that is tailored to your
activities on the platform and outside the platform.
● Data used: Data provided by you, automatically collected
Data and data from other sources for this purpose.
Your rights: Whenever we process your data based on your consent
use, you can revoke your consent at any time. The revocation of your
However, consent does not affect the legality of the processing of your data
based on your consent before withdrawing your consent. You can
Your consent to the corresponding settings for personalized advertising
revoke by writing a message to info@soulside.app with the following
Text:
Template Starts Here:
“I (your name) have an account named (Account Name) at Soulside and
would like to revoke my consent to the use of my data by Soulside.
The current date”
You also have the right to information you have provided to us
and which we use on the basis of your consent.
Fulfillment of a legal obligation
We may share your information, including your profile information or
User Content, if this is necessary to comply with a legal
This includes situations where we are obliged
are to take measures to ensure the security of our users
or to comply with a lawful request, such as a warrant to
Disclosure by government agencies, law enforcement agencies or
Courts. We normally use the data you provide
and automatically collected data, although this depends on the specific situation.
Fulfillment of a task in the public interest
We may use your information if this is necessary to perform a task in the
necessary in the public interest, including the implementation of
research, prevention and detection of crime, protection
of children and the promotion of public safety and integrity in accordance with the
applicable laws. We normally use the information you provide
provided data and automatically collected data, whereby this is determined by the
depends on the respective situation.
Your rights: If we use your data on the basis that it is necessary for
task is necessary in the public interest, you have the right to object to our
to object to the use and to request a restriction in this regard.
demand.
Protection of essential interests of persons
We may use your information if it is necessary to protect the life,
physical integrity or safety of you or any other person
This may involve the transmission of data to law enforcement authorities
or emergency services in urgent situations to protect health or life
We normally use the data you provide and
automatically collected data, although this depends on the situation
depends.
Your rights and choices
You have rights and choices when it comes to your data. Some
Some of these rights apply generally, while others apply only under specific circumstances.
Depending on the situation, these rights may be subject to restrictions.
Soulside GmbH is responsible for answering your request within the legally
responsible for the prescribed deadlines.
Information about your data. You can ask us to confirm
what data we process about you, provide you with certain data about the
processing and to receive a copy of your data, each free of charge
for you. With the in-app controls you can:
● access your data that is available to other users by
You navigate to the “Profile” tab in your account.
● request a copy of your data by using the tool “Your data
Download". Click here for detailed instructions.
Deleting your data. You can delete your data or ask us to delete it completely or
partially delete. With the in-app controls you can:
● delete the content published in your profile, such as your User Content
and your profile information.
● Delete your entire account.
● the deletion of a specific content using the in-app reporting function
apply for.
Correction of your data. You can change your data or ask us to
to change or correct this data if it is not correct. You can do many
Change or correct your data via the in-app controls and settings (e.g.
B. your profile information and video content).
Portability of your data. You have the right to data portability in
Cases in which we rely on contractual necessity and consent as
This means that you have the right to have your data
in a structured, common and machine-readable format and
to a third party. You can exercise your right to
Make use of data portability by sending us an e-mail to:
info@soulside.app
Objection to the processing of your data. Under certain circumstances, you have
You also have the right to object to the processing of your data
This right exists if we perform a task in the public interest
pursue our legitimate interests or those of a third party or
if, under certain circumstances, your data is processed for the purpose of facilitating
scientific or historical research. If you have a
To object, please provide all relevant information,
including the processing to which you object, why you
wish to object and how the processing affects you, as well as all
any additional information you believe will help us to assess your request
We will stop the processing in question if we no longer need
have compelling legitimate grounds to continue such processing, or where
we do not need it for legal claims.
Restriction of the processing of your data. You have the right to
To request restriction of processing of your data if (a) you have
complain about the accuracy of the data, (b) the data have been processed unlawfully,
but you object to the deletion of this data, (c) the data is used for tracking
or defense of a legal claim, or (d) you
have objected to the processing and the result of this
Wait for the objection request.
To exercise the above rights, please contact us via email
to: info@soulside.app
Before we respond to a request to exercise one or more of the above
To respond to your rights, you may need to disclose your identity or
Confirm account information or provide additional information,
so that the application can be traced.
Please use the “Contact” function if you are not satisfied with the way we
you have responded to any of your requests relating to your rights. You have
also the right to lodge a complaint with the Irish Data Protection Commission (the
Soulside GmbH's supervisory authority) or the competent
supervisory authority.
In addition to these rights, you can change the privacy settings for your account
adjust.
Data security and retention
The security of your data is important to us. We take appropriate technical,
administrative and physical security measures to protect your data from
unauthorized access, theft, disclosure, alteration or loss. We
We regularly review our security measures to identify new and available
technologies and methods must be taken into account.
We retain your data for as long as necessary to provide the platform and
is necessary for the other purposes set out in this privacy policy.
We also store the data if this is necessary to fulfil contractual and
legal obligations is necessary if we have a legitimate
have a business interest in doing so (e.g. to improve and develop the
Platform and to improve the security and stability of our services) and
to assert or defend legal claims.
The retention periods depend on the type of data and the purposes for which we
use the data differently. For example, if we use your data
process to provide you with the Platform, we will retain this
Data for as long as you have a Soulside account. This data includes
Your profile information, user content and direct messages. If you object to
our policies or terms of use, we may
Profile information and/or user content immediately from public view
remove, but keep your data for as long as necessary to process the
infringement is necessary.
Our global activities and
Data transfers
To support our global activities:
● We store the information described in the “Information we collect” section
described information on servers in the USA and Europe.
● We share the information described in the “Information We Collect” section
with service providers and other third parties as described in the section “How we
personal data”. These third parties may
may also be located outside your country of residence.
These third parties are obliged to use the personal data exclusively
in accordance with applicable data protection laws and taking
appropriate security measures to protect your personal
to process data.
If we transfer your information outside the EEA, the UK or the
Switzerland, we will ensure that it is processed in accordance with an appropriate
Data protection level:
● Adequacy decisions. These are decisions
the European Commission pursuant to Article 45 GDPR (or equivalent
laws) that determine that a country has an adequate
We transmit your personal data,
mentioned in the section “Information we collect” to countries for which
the adequacy decisions are available.
● Standard contractual clauses. The European Commission has standard contractual clauses
pursuant to Article 46 of the General Data Protection Regulation, which allows
Allow companies in the EEA to transfer data to countries outside the EEA
These clauses (and their recognised equivalents in the
United Kingdom and Switzerland) are considered
Standard contractual clauses.
Minor users
You must be at least 13 years old to use the Platform. If
If you believe that a user has not yet reached this minimum age, report
Please send us an email to: info@soulside.app
In order to provide an age-appropriate experience for users under 18, certain
Functions and content not available.
Privacy Policy Updates
We may change or update this privacy policy from time to time.
We will notify you of any material changes to this Privacy Policy
by means of a notice on the platform or by other means.
The “Last Updated” date at the top of this Privacy Policy is the date
of the entry into force of such changes.
You can contact our data protection officer here:
Project 29 GmbH & Co. KG
Ostengasse 14
93047 Regensburg
Phone: 0941-298693-19
www.projekt29.de
EEA/UK/CH - english
Data Protection Directive
Date of entry into force: November 19, 2023
Introduction
This Privacy Policy (“Privacy Policy”) applies to the processing of personal data by the
Soulside App in connection with Soulside's applications, websites, software and related
services (the “Platform”) that link or refer to this Privacy Policy.
Data Controller: If you live in the European Economic Area ("EEA"), the United Kingdom
(UK) or Switzerland, Soulside GmbH is a German-based company for the processing of your
data in connection with this Privacy Policy.
Information we collect
We collect your data in three ways: data provided by you, data collected automatically and
data from other external sources. Further details are set out below.
Data provided by you
● Profile information. We collect data that you provide when setting up
account, such as your date of birth, your username, your e-mail address
and/or telephone number and your password. You can add further information
to your profile, such as a description or a profile photo.
● User content. We collect the content you create or publish via the platform,
such as photos, videos, audio recordings, live streams, comments, hashtags,
feedback and reviews, as well as the associated metadata (eg when, where
and by whom the content was created). Even if you are not a user, information
about you may appear in content created or published by users on the
platform.platform. We collect user content by preloading it at the time of creation,
import or upload, regardless of whether you save or upload this user content,
eg to recommend music based on the video. We also collect content (eg
text, images and videos) from your device's clipboard when you copy and
paste content onto the Platform or share content between the Platform and a
third-party platform.
● Direct messages. When you communicate with others via direct messages,
we collect the content of the message and the associated metadata (eg the
time the message was sent, received and/or read, and the participants in the
communication). We also collect messages that you send or receive via us
chat function when you communicate with merchants who sell you goods via
Soul side.
● Your contacts. When you synchronize your contacts, we access data from
your device's phonebook, such as names, phone numbers and email
addresses, and match this data with users on the Platform. When you add
other users through your social network contacts, we collect your public profile
information and the names and profiles of your social network contacts.
● Purchase information. When you make a purchase or payment on or through
the Platform, including when you purchase Soulside Coins or merchandise
Through our shopping features, we collect information about the purchase or
payment transaction, such as payment card information, billing, shipping and
contact information, and the items you purchase.
● Surveys, research and promotions. We collect information provided by you
when you choose to participate in a survey, research, promotion, contest,
marketing campaign or event conducted or sponsored by us.
● When you contact us. When you contact us, we collect the information from you
send us, such as proof of identity or age, feedback or requests about your use
of the Platform, or information about possible violations of our Terms of Use
(our "Terms of Use"), Community Guidelines (our "Guidelines") or others
policies.
● Information from forms and features you use. We collect the information you
provide when you fill out a form on the Platform. You can have Soulside
Sign in auto-fill forms with your account information, such as your addresses
or payment information.
Automatically recorded data
● Technical data. We collect certain device and network connection data when
you access the platform. This information includes your device model,
operating system, keystroke patterns or rhythms, IP address and system
language. We also collect service-related, diagnostic and performance data,
including crash reports and performance logs. We automatically assign you a
device ID and a user ID. If you log in from multiple devices, we use data such
as your device ID and user ID to identify your activity across devices so that
we can provide you with a seamless login experience, as well as for security
reasons.
● Information about usage. We collect data about how you use our platform,
including data about the content you view, the duration and frequency of your
use, how you engage with other users, your search history and your
preferences.
● Content characteristics and features. We recognize and collect features and
characteristics of the video, image and audio recordings that are part of your
User Content, for example by identifying objects and landscapes, the
presence or position of a face or other body parts within an image and the text
of words spoken in your user content. We do this, for example, for content
moderation and to provide special effects (such as video filters and avatars)
and subtitles.
● Inferred data. We infer your characteristics (eg age group and gender) and
interests from the data we hold about you. We use these inferences, for
example, to keep our Platform secure, to moderate content and, where
permitted, to provide you with personalized advertising based on your
interests.
● Cookies. We use cookies and similar tracking technologies to operate and
provide our services. For example, we use cookies to remember your
language preferences, to ensure that you do not watch the same video anymore
than once, and for security purposes. We also use these technologies for
marketing purposes. Where required by law, we will obtain your consent to the
use of cookies.
Data from other sources
● Advertising, measurement and data partners. Advertisers, measurement
services and other partners share information with us about you and your
behavior outside of the Platform, such as your activity on other websites and
apps or in stores, including the products or services you have purchased
online or in person. These partners also share data with us such as mobile
identifiers for advertising, hashed email addresses and cookie identifiers
● Merchants, payment and transaction service providers. We receive
information about you from merchants and payment and transaction service
providers, such as details of payment confirmations and delivery information
for products you have purchased through our shopping features.
How we use your personal data
We use your data to operate, provide, develop and improve our services, including
for the following purposes.
● Provide and administer our Services, for example, to enable you to create,
share and consume content and interact with other users and their content.
● Providing our shopping feature and facilitating the purchase and delivery of
products, goods and services, including sharing your information with
merchants, payment and transaction service providers and other service
providers to process your orders.
● Personalize and customize certain features and content on the Platform, such
as providing your "For You" feed.
● Enforce our Terms of Use, policies and other terms that apply to you. We
review user content and other information through a combination of
technological tools (including automated solutions) and human moderation to
protect the safety and well-being of our community.
● Provide certain interactive features, such as the ability to use your content in
other users' videos and suggest your account to other users to connect you
with other users.
● Providing and improving our advertising services, including serving ads
(including personalized ads where permitted) and measuring and
understanding the effectiveness of the ads and other content.
● Maintaining and improving the security and stability of our services by
identifying and fixing technical or security issues (eg technical bugs, spam
accounts, detection of abuse, fraud and illegal activity).
● Review, improve and develop the Platform, including by monitoring
interactions and usage across your devices, analyzing how users use the
Platform and training, testing and improving our technology, such as us
machine learning models and algorithms.
● Promote the Platform or third party services through marketing
communications, contests or promotions.
● To comply with our legal obligations or to perform tasks that are in the public
interest or to protect the vital interests of our users and others.
How we share your personal data
Service providers
We use service providers to help us provide, support and develop our services
understand how they are used. They provide the following services, among others:
● Cloud hosting and content provision,
● Customer care and technical support
● Content moderation
● marketing
● Analytics and online payments
We pass on the data provided by you, automatically collected data and data from
other sources to these service providers, insofar as this is necessary for them to
provide their services.
partner
Third-party platforms and partners. We share limited information, which may include
the data you provide, technical data and usage information, with third-party platforms
and partners whose platform or services are integrated with the Platform. We do this
to provide you with a seamless experience and allow you to share your content on
other platforms, and/or to allow third-party platforms and partners to better
authenticate users. For example, if you choose to:
● log in or sign in to the Platform using your account information from a third party
party platform (eg Facebook or Google), we will share certain technical data
to enable this;
● share user content that you post on the platform on other social media
platforms, we will share your user content and related data.
Advertising Partners. We provide advertisers with aggregated data about the
performance of their ads and other content on the Platform to help them measure
their effectiveness. We create this aggregated data using the data you provide,
automatically collected data and data from other sources. We will share your data
directly with advertisers if you give us permission to do so.
Measurement and data partners. We also share the data you provide, your technical
data and usage information with third parties who help us measure advertising on
our platform and help our advertisers determine the effectiveness of their advertising.
Merchants, payment and transaction service providers and other service providers.
When you make a purchase through the shopping features on our platform, we
share purchase information about the transaction with the merchant, payment and
transaction service providers and other service providers. For example, we pass on
details of the item ordered, contact details and delivery information so that your order
can be processed. We may also disclose certain technical information about you
device or connection type to these parties to ensure the security of the transaction.
Other
We share your data in some other scenarios as follows:
Users and the public. Depending on your privacy settings, your information, including yours
profile information, user content and usage information, may be visible to other users and
the public. For example, if you have a public account and have not individually restricted the
visibility of your posts, your profile information and user content may be viewed or shared by
anyone on or off the Platform, whether or not that person has a Soulside account.
Depending on your privacy settings, your profile information and user content may also
appear on search engines, content aggregators and news sites.
Users of our analytics services. We provide aggregated statistics and insights to help people
and businesses understand how the platform is being used. For example, creators and
advertisers can receive information about the number of views, likes, comments and shares
of their videos, as well as demographic information about their followers and the viewers of
their videos. We create this aggregated data using the data you provide and automatically
collected data.
Corporate transactions. Your information may be shared with third parties in connection with
a corporate transaction such as a merger, sale of assets or shares, reorganization, financing,
change of control or acquisition of all or a portion of our business.
Legal obligations and rights. We may access, preserve and disclose the information
described under "Information We Collect" to law enforcement, government agencies,
copyright owners or other third parties if we have a good faith belief that such
action is necessary to:
● Comply with applicable law and legal process or comply with governmental
requests in accordance with internationally recognized standards;
● protect the rights, property and safety of our users, copyright owners and
others, including the protection of human life or the prevention of imminent
physical harm. For example, we may disclose information (such as your IP
address) to law enforcement authorities in an emergency if there is a threat to
the life or safety of any person;
● investigate and enforce possible violations of our Terms of Use, policies or
other applicable regulations, guidelines or standards; or
● detect, investigate, prevent, or take action regarding deceptive activities,
copyright infringement, or other illegal activities.
For more information on how we handle requests from law enforcement and public
authorities, please refer to our Law Enforcement Data Request Policy.
Our legal bases and how we process yours
personal data
We only use your data if we have a “legal basis” for doing so. Depending on why we
use your data (in other words, depending on the "purpose" of our processing), we
use different legal bases. These legal bases include contractual necessity, legitimate
interests (ours, yours or those of another party), consent, compliance with a legal
obligation, performance of a task carried out in the public interest and protection of
vital interests.
Here we explain the legal bases we rely on to process your data. This section also
describes why we use your data, how this data is processed, what categories of data
are involved and what rights are associated with this (which always includes the right
of access to your data). For more information on how you can exercise your rights,
please refer to the section "Your rights and choices" in the Privacy Policy.
Contractual necessity
For all persons who are legally capable of entering into an enforceable contract, we
use the data you provide, automatically collected data and data from other sources if
this is necessary to fulfill the contract you enter into when registering, accessing or
using the platform (our terms of use). This means that we use your data to:
● Provide you with the platform. We use your information to enable you to
access and use the Platform, including the ability to create and consume
content, interact with others, use social features, and offer you products and
services that you purchase. We also personalize certain features and content
on the Platform, such as by providing your "For You" feed, showing you
videos that we think would interest you and suggesting accounts.
● Product orders and deliveries. We use your data to process orders, for
example to enable the purchase and delivery of products, and to send you
messages about your orders. This includes sharing purchase information with
merchants, payment and transaction service providers and other service
providers
● Enforce our terms of use, policies or regulations. We use your information to
enforce our terms of use, policies and guidelines (including automated
solutions and human moderation). This may include age-restricting adults
content, maintaining our For You Feed eligibility standards, removing content
or suspending your account if we determine that you are in violation of ours
Terms of Service or policies.
● To administer our services. We also use the information we hold to administer
our Services, for example, to communicate with you in relation to the Service,
to keep you informed or assist you in relation to your purchases made through
the Platform and to deal with your queries, claims or complaints (including
notifying you of a problem or requesting a copy of your information).
Your rights: Whenever we process your data because this is necessary for the
contract we have concluded with you, you have the right to have the data you have
provided.
Legitimate interests
We use your data if this is necessary to safeguard legitimate interests - regardless of
whether these concern us, you or a third party - provided that these interests are not
outweighed by your interests or fundamental rights and freedoms. We use your data
to:
To enable the use of your videos in interactive functions.
● Our interactive features such as Duet and Stitch allow other users to embed
your videos in their own videos (if you allow this in your settings).
● Legitimate interest that we rely on: To provide users with tools that inspire
creativity, collaboration and enjoyment, and to enable users to reach new
audiences.
● Data used: Data provided by you and automatically collected data.
Suggest your account to other users.
● We may suggest your account to other users, eg if a user synchronizes them
contacts with the platform.
● Legitimate interest that we rely on: To enable users to quickly and efficiently
find and connect with other users on our platform.
● Data used: Data provided by you, automatically collected data and data from
other sources.
To provide non-personalized advertising to all users.
● We show non-personalized advertising to all users, including those who have
opted out of personalized advertising.
● Legitimate interest to which we refer: We show non-personalized advertising
so that we can continue to offer the platform free of charge. We process
limited categories of your data to ensure that our advertising service is useful
to our advertisers (for example, to show ads to users in a particular country or
users who speak the same language).
● Data used: Data provided by you and data collected automatically.
Measurement and analysis services.
● We help creators and advertisers measure the effectiveness and distribution
of ads and other content displayed on the platform.
● Legitimate interest that we rely on: So that creators and advertisers can see
and understand how their ads or content are performing and which audiences
are viewing or interacting with their ads or content. This allows them to make
informed decisions (eg about what type of advertising campaigns to run,
what audience to reach and what content users like best). This helps too
ensure that the advertising and other content we show to users remains
relevant and entertaining, and that the platform remains free for all users.
● Data used: Data provided by you, automatically collected data and data from
other sources.
To ensure the safety and well-being of our community.
● We use your information to ensure the safety and well-being of us
community, including reviewing user content (and, where permitted by
applicable law, direct messages and associated metadata) for violations of our
Terms of Service, policies and other terms. We also estimate your age group
and may ask you for additional information to confirm your age.
● Legitimate interest we rely on: To ensure the safety of our community, to verify
compliance with our policies and to detect misuse of the platform.
● Data used: Data provided by you, automatically collected data and data from
other sources.
To ensure the security and stability of the platform.
● We use your data to ensure the stability and security of the platform, including
the identification and resolution of technical or security issues (such as
technical bugs, spam accounts and the detection of abuse, fraud and illegal
activities).
● Legitimate interest on which we rely: To ensure the stability and security of the
platform and to ensure that it is constantly available and functional.
● Data used: Data provided by you, automatically collected data and data from
other sources.
To review, improve, promote and further develop the platform.
● We use the data available to us to understand how the Platform is used by
users and to further develop, test and improve the Platform, including
developing and improving our technology, such as our machine learning
models and algorithms. We also use this information to better understand and
promote the Platform, popular topics and emerging trends.
● Legitimate interest we rely on: Improving, promoting and developing the
platform in an informed way.
● Data used: Data provided by you, automatically collected data and data from
other sources.
Enable communication for marketing purposes.
● We may send you direct marketing messages about features of our Services
and third party services that we think may interest you. We may also send you
promotions, competitions, marketing campaigns or events. We will obtain your
consent to send you such messages where required by law.
● Legitimate interest on which we rely: To promote the Platform or third party
products and services.
● Data used: Data provided by you, automatically collected data and data from
other sources.
Your rights: Whenever we use your data on the basis of legitimate interests, you can
object to this and request the restriction of its use.
If you are under the age of majority (under 18 in most relevant countries) and
of limited capacity to enter into an enforceable contract and we are unable to
process your data due to contractual requirement, we will rely on legitimate
interests and use the data we collect to:
Provide you with the Platform
● We use your data to enable you to access and use the Platform, including the
ability to create, share and consume content, interact with others, use
features and offer you products and services that you purchase.
● Legitimate interest we rely on: To provide, support and maintain products and
features that allow users to interact with, discover, engage with or express
themselves through content without the possibility of an enforceable contract
with us. We also rely on the legitimate interest of our users to be able to use
the platform in a simple and intuitive way.
● Data used: Data provided by you, automatically collected data and data from
other sources.
Personalize features and content
● We also personalize certain features and content on the Platform based on
your data, for example by providing you with your "For You" feed, showing you
videos that we think you would be interested in and suggesting accounts.
● Legitimate interest we rely on: Providing, supporting and maintaining products
and features that allow users, without the possibility of an enforceable
contract with us, to communicate, discover, engage with content that matches
their interests. We also rely on the legitimate interest of our users who cannot
enter into an enforceable contract with us to access the platform and content
that matches their interests.
● Data used: Data provided by you, automatically collected data and data from
other sources.
To enforce our terms of use, policies or guidelines.
● We use your information to enforce our terms of use, policies and guidelines
(including automated solutions and human moderation). This may include
age-restricting adult content, maintaining our For You Feed eligibility
standards, removing content or suspending your account if we find that you
are in breach of our terms of use or policies.
● Legitimate interest we rely on: To keep the Platform free of harmful or
inappropriate content, to investigate suspicious activity or violations of ours
Terms of Service, policies or guidelines, and to protect the safety of users who
cannot enter into an enforceable contract with us, including to prevent
exploitation or other harm to which these individuals may be particularly
vulnerable. This is also in the legitimate interests of our users who cannot
enter into an enforceable contract with us, and the public in general, to determine
bad experiences and promote safety, integrity and security.
● Data used: Data provided by you, data collected automatically and data from
other sources.
Manage our services.
● - We use the data we hold to administer the Platform, eg to communicate
with users and to respond to and deal with queries, claims or complaints
(including notifying you of a problem or requesting a copy of your data).
● Legitimate interest on which we rely: To provide meaningful information about
service-related matters to our users who cannot enter into an enforceable
contract with us and to deal with their inquiries, claims and disputes.
● Data Used: Data provided by you, data collected automatically and data from
other sources.
Your rights: Whenever we use your data on the basis of legitimate interests,
you can object to this and request the restriction of its use.
Your consent
We obtain your consent to access your data or to use it for certain purposes. If we do
this, you can withdraw your consent at any time via the device permissions or in-app
settings.
Personalized advertising.
With your consent, we will show you personalized advertising based on yours
activities on and off the platform.
Data used: Data provided by you, automatically collected data and data from others
sources for this purpose.
Your rights: Whenever we use your data on the basis of your consent, you can
withdraw your consent at any time. However, the withdrawal of your consent does
not affect the lawfulness of the processing of your data based on your consent prior
to the withdrawal of consent. You can withdraw your consent to the relevant settings
for personalized advertising by writing a message to info@soulside.app with the
following text:
Template starts here:
"I (your name) have an account with the name (account name) at Soulside and
would like to revoke my consent to the use of my data at Soulside.
The current date"
You also have the right to have information that you have provided to us and that we
use on the basis of your consent transferred.
Fulfillment of a legal obligation
We may use your information, including your profile information or user content,
when necessary to comply with a legal obligation. This includes situations where we
are required to take steps to ensure the safety of our users or to comply with a lawful
request, such as a disclosure order from government authorities, law enforcement
agencies or courts. Normally, we use the data you provide and automatically
collected data, depending on the situation.
Fulfillment of a task in the public interest
We may use your data where it is necessary for the performance of a task carried
out in the public interest, including carrying out research, preventing and detecting
crime, protecting children and promoting public safety and integrity in accordance
with applicable laws. We will normally use the data you provide and automatically
collected data for this purpose, depending on the situation.
Your rights: If we use your data on the basis that it is necessary for a task carried out
in the public interest, you have the right to object to our use and to request that it be
restricted.
Protection of essential interests of persons
We may use your data if this is necessary to protect the life, physical integrity or
safety of you or another person. This may include the transmission of data to law
enforcement authorities or emergency services in urgent situations to protect health
or life. Normally, we will provide the data you provide and automatically collected
data for this purpose, depending on the situation.
Your rights and options
You have rights and choices when it comes to your data. Some of these rights apply
generally, while others only apply in certain circumstances. Depending on the
situation, these rights may be subject to restrictions. Soulside GmbH is responsible
for responding to your request within the time limits prescribed by law.
Information about your data. You can ask us to confirm what data we are processing
about you, provide you with specific details about the processing and obtain a copy
of your data, in each case at no cost to you. With the in-app controls you can:
● access your data that is available to other users by navigating to the "Profile"
tab in your account.
● Request a copy of your data by using the "Download your data" tool. Click
here for detailed instructions.
Deleting your data. You can delete your data or ask us to delete all or part of it. With
the in-app controls you can:
● Delete the content published in your profile, such as your user content and
your profile information.
● Delete your entire account.
● Request the deletion of specific content using the in-app reporting function.
Correction of your data. You can change your data or ask us to change or correct it if
it is incorrect. You can change or correct much of your data via the in-app controls
and settings (eg your profile information and video content).
Portability of your data. You have the right to data portability in cases where we rely
on contractual necessity and consent as the legal basis. This means that you have
the right to receive your data in a structured, commonly used and machine-readable
format and to transmit it to a third party. You can exercise your right to data portability
by sending us an email to:
info@soulside.app
Objection to the processing of your data. You also have the right to object to that
processing of your data in certain circumstances. This right exists where we are
carrying out a task in the public interest, pursuing our legitimate interests or those of
a third party, or where your data is being processed for the purpose of facilitating
scientific or historical research in certain circumstances. If you make an objection,
please provide all relevant information, including the processing you are objecting to,
why you want to object and how the processing affects you, as well as any additional
information you think will help us to consider your request. We will stop that
processing in question if we have no legitimate grounds to continue that
processing or if we do not need it for legal claims.
Restriction of the processing of your data. You have the right to request the
restriction of the processing of your data if (a) you contest the accuracy of the data,
(b) the data has been processed unlawfully but you oppose the erasure of that data,
(c) the data needs to be retained for the establishment, exercise or defense of a
legal claim, or (d) you have objected to the processing and are awaiting the outcome
of that objection request.
To exercise the above rights, please contact us via email at:
info@soulside.app
Before we can respond to a request to exercise one or more of the above rights, you
may be required to confirm your identity or account information or provide additional
information so that the request can be tracked.
Please use the "Contact Us" function if you are not satisfied with the way we have
responded to any of your rights requests. You also have the right to lodge a
Complaint with the Irish Data Protection Commission (the supervisory authority
responsible for Soulside GmbH) or with your local supervisory authority.
In addition to these rights, you can adjust the privacy settings for your account.
Data security and storage
The security of your data is important to us. We take appropriate technical,
administrative and physical security measures to protect your data from
unauthorized access, theft, disclosure, alteration or loss. We regularly review ours
security measures to take account of available new technologies and methods.
We will retain your information for as long as necessary to provide the Platform and
for the other purposes set out in this Privacy Policy. We also retain the data if this is
necessary to fulfill contractual and legal obligations, if we have a legitimate business
interest in doing so (eg to improve and develop the platform and to improve the
security and stability of our services) and to assert or defend legal claims.
The retention periods vary depending on the type of data and the purposes for which
we use the data. For example, if we process your data to provide you with the
platform, we will retain this data for as long as you have a Soulside account. This
data includes your profile information, user content and direct messages. If you
violate our policies or terms of use, we may remove your profile information and/or
user content from public view immediately, but retain your data for as long as
necessary to process the violation.
Our global activities and data transfers
To support our global activities:
● We store the information described in the "Information we collect" section on
servers in the United States and Europe.
● We share the information described in the "Information we collect" section
with service providers and other third parties as described in the "How we
share your personal information" section. These third parties may also be
located outside your country of residence.
These third parties are obliged to process the personal data only in accordance with
the applicable data protection laws and by taking appropriate security measures to
protect your personal data.
If we transfer your data outside the EEA, the United Kingdom or Switzerland, we will
ensure that it is treated in accordance with an adequate level of data protection:
Adequacy decisions. These are decisions by the European Commission under
Article 45 GDPR (or equivalent legislation) which determines that a country provides
an adequate level of data protection. We transfer your personal data identified in the
"Information we collect" section to countries for which adequacy decisions have been
made.
Standard Contractual Clauses. The European Commission has approved contractual
clauses under Article 46 of the General Data Protection Regulation that allow
companies in the EEA to transfer data outside the EEA. These clauses (and their
approved equivalents in the UK and Switzerland) are known as Standard Contractual
Clauses.
Minors
You must be at least 13 years old to use the platform. If you believe that a user has
not yet reached this minimum age, please notify us by email: info@soulside.app
In order to provide an age-appropriate experience for users under the age of 18,
certain features and content are not available.
Updates to the privacy policy
We may change or update this Privacy Policy from time to time. We will notify you of this
any material changes to this Privacy Policy by posting a notice on the Platform or by
other means. The "Last Updated" date at the top of this Privacy Policy is the effective
date of such changes.
You can contact our data protection officer here:
Project 29 GmbH & Co. KG
Ostengasse 14
93047 Regensburg
Phone: 0941-298693-19
www.projekt29.de
US
Privacy Policy
Last updated: May 22, 2023
This Privacy Policy applies to Soulside services (the “Platform”), which include
Soulside apps, websites, software and related services accessed via any platform or
device that links to this Privacy Policy. The Platform is provided and controlled by
Soulside Inc. (“Soulside”, “we” or “us”). We are committed to protecting and
respecting your privacy. This Privacy Policy explains how we collect, use, share, and
otherwise process the personal information of users and other individuals age 13
and over in connection with our Platform. For information about how we collect, use,
share, and otherwise process the personal information of users under age 13
(“Children”), please refer to our Children's Privacy Policy.
Capitalized terms that are not defined in this Privacy Policy have the meaning given
to them in the Terms of Service.
What Information We Collect
We may collect information from and about you, including information that you
provide, information from other sources, and automatically collected information.
Information You Provide
When you create an account, upload content, contact us directly, or otherwise use
the Platform, you may provide some or all of the following information:
● Account and profile information, such as name, age, username, password,
language, email, phone number, social media account information, and profile
image.
● User-generated content, including comments, photographs, livestreams,
audio recordings, videos, text, hashtags, and virtual item videos that you
choose to create with or upload to the Platform (“User Content”) and the
associated metadata, such as when, where, and by whom the content was
created. Even if you are not a user, information about you may appear in User
Content created or published by users on the Platform. When you create User
Content, we may upload or import it to the Platform before you save or post
the User Content (also known as pre-uploading), for example, in order to
recommend audio options, generate captions, and provide other personalized
recommendations. If you apply an effect to your User Content, we may collect
a version of your User Content that does not include the effect.
● Messages that include information you provide when you compose, send,
or receive messages through the Platform's messaging functionalities. They
include messages you send through our chat functionality when
communicating with merchants who sell goods to you, and your use of virtual
assistants when purchasing items through the Platform. That information
includes the content of the message and information about the message,
such as when it was sent, received, or read, and message participants.
Please be aware that messages you choose to send to other users of the
Platform will be accessible by those users and that we are not responsible for
the manner in which those users use or share the messages.
● Information, including text, images, and videos, found in your device's
clipboard, with your permission. For example, if you choose to initiate
information sharing with a third-party platform, or choose to paste content
from the clipboard onto the Platform, we access this information stored in your
clipboard in order to fulfill your request.
● Purchase information, including payment card numbers or other third-party
payment information (such as PayPal) where required for the purpose of
payment, and billing and shipping address. We also collect information that is
required for extended warranty purposes and your transaction and purchase
history on or through the Platform.
● Your phone and social network contacts, with your permission. If you choose
to find other users through your phone contacts, we will access and collect
information such as names, phone numbers, and email addresses, and match
that information against existing users of the Platform. If you choose to find
other users through your social network contacts, we will collect your public
profile information as well as names and profiles of your social network
contacts.
● Your choices and communication preferences.
● Information to verify an account such as proof of identity or age.
● Information in correspondence you send to us, including when you contact us
for support.
● Information you share through surveys or your participation in challenges,
research, promotions, marketing campaigns, events, or contests such as yours
gender, age, likeness, and preferences.
Information From Other Sources
We may receive the information described in this Privacy Policy from other sources,
such as:
● If you choose to sign-up or log-in to the Platform using a third-party service
search as Facebook, Twitter, Instagram, or Google, or link your Soulside
account to a third-party service, we may collect information from the
service–for example, your public profile information (such as nickname),
email, and contact list.
● Advertisers, measurement and other partners share information with us about
you and the actions you have taken outside of the Platform, such as yours
activities on other websites and apps or in stores, including the products or
services you purchased, online or in person. These partners also share
information with us, such as mobile identifiers for advertising, hashed email
addresses and phone numbers, and cookie identifiers, which we use to help
match you and your actions outside of the Platform with your Soulside
account. Some of our advertisers and other partners enable us to collect
similar information directly from their websites or apps by integrating our
Soulside Advertiser Tools (such as Soulside Pixel).
● We may obtain information about you from certain affiliated entities within us
corporate group, including about your activities on their platform.
● We may receive information about you from others, including where you are
included or mentioned in User Content, direct messages, in a complaint,
appeal, request or feedback submitted to us, or if your contact information is
provided to us. We may collect information about you from other publicly
available sources.
Automatically Collected Information
We automatically collect certain information from you when you use the Platform,
including internet or other network activity information such as your IP address,
geolocation-related data, unique device identifiers, browsing and search history
(including content you have viewed in the Platform), and Cookies.
● Usage information. We collect information regarding your use of the Platform
and any other User Content that you generate through or upload to us
Platform.
● Device information. We collect certain information about the device you use
to access the Platform, such as your IP address, user agent, mobile carrier,
time zone settings, identifiers for advertising purposes, model of your device,
the device system, network type, device IDs, your screen resolution and
operating system, app and file names and types, keystroke patterns or
rhythms, battery state, audio settings and connected audio devices. We
automatically assign you a device ID and user ID. Where you log in from
multiple devices, we will be able to use information such as your device ID
and user ID to identify your activity across devices. We may also associate
you with information collected from devices other than those you use to log-in
to the Platform.
● Location data. We collect information about your approximate location,
including location information based on your SIM card and/or IP address. In
In addition, we collect location information (such as tourist attractions, shops, or
other points of interest) if you choose to add the location information to your
User content. Current versions of the app do not collect precisely or
approximate GPS information from US users. If you are still using an older person
version that allowed for collection of precise or approximate GPS information
(last release in August 2020) and you granted us permission to do so, we may
collect such information.
● Image and Audio Information. We may collect information about the videos,
images and audio that are a part of your User Content, such as identifying the
objects and scenery that appear, the existence and location within an image
of face and body features and attributes, the nature of the audio, and the text
of the words spoken in your User Content. We may collect this information to
enable special video effects, for content moderation, for demographic
classification, for content and ad recommendations, and for others
non-personally identifying operations. We may collect biometric identifiers and
biometric information as defined under US laws, such as faceprints and
voiceprints, from your User Content. Where required by law, we will seek any
required permissions from you prior to any such collection. Click here to learn
more.
● Metadata. When you upload or create User Content, you automatically
upload certain metadata that is connected to the User Content. Metadata
describes other data and provides information about your User Content that
will not always be evident to the viewer. For example, in connection with your
User Content the metadata can describe how, when, where, and by whom the
piece of User Content was created, collected, or modified and how that
content is formatted. It also includes information, such as your account name,
that enables other users to trace back the User Content to your user account.
Additionally, metadata includes data that you choose to provide with your
User Content, eg, any hashtags used to mark keywords to the video and
captions.
● Cookies. We and our service providers and business partners use cookies
and other similar technologies (eg, web beacons, flash cookies, etc.)
(“Cookies”) to automatically collect information, measure and analyze how
you use the Platform, including which pages you view most often and how you
interact with content, enhance your experience using the Platform, improve
the Platform, provide you with advertising, and measure the effectiveness of
advertisements and other content. We and our partners also use cookies to
promote the Platform on other platforms and websites. Cookies enable the
Platform to provide certain features and functionality. Web beacons are very important
small images or small pieces of data embedded in images, also known as
“pixel tags” or “clear GIFs,” that can recognize cookies, the time and date a
page is viewed, a description of the page where the pixel tag is placed, and
similar information from your computer or device.
We may link your contact or account information with your activity on and off ours
Platform across all your devices, using your email or other log-in or device
information. We may use this information to display advertisements on our platform
tailored to your interests, preferences, and characteristics.
We are not responsible for the privacy practices of our service providers and
business partners, and the information practices of these service providers and
business partners are not covered by this Privacy Policy.
We may aggregate or de-identify the information described above. Aggregated or
de-identified data is not subject to this Privacy Policy.
How We Use Your Information
As explained below, we use your information to improve, support and administer the
Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of
Service. We may also use your information to, among other things, show you
suggestions, promote the Platform, and customize your ad experience.
We generally use the information we collect:
● To fulfill requests for products, services, platform functionality, support and
information for internal operations, including troubleshooting, data analysis,
testing, research, statistical, and survey purposes and to solicit your feedback.
● To customize the content you see when you use the Platform. For example,
we may provide you with services based on the country settings you have
chosen or show you content that is similar to content that you have liked or
interacted with.
● To send promotional materials from us or on behalf of our affiliates and trusted
third parties.
● To improve and develop our Platform and conduct product development.
● To measure and understand the effectiveness of the advertisements we serve
to you and others and to deliver advertising, including targeted advertising, to
you on the Platform.
● To make suggestions and provide a customized ad experience.
● To support the social functions of the Platform, including to permit you and
others to connect with each other (for example, through our Find Friends
function), to suggest accounts to you and others, and for you and others to
share, download, and otherwise interact with User Content posted through the
Platform.
● To use User Content as part of our advertising and marketing campaigns
promote the Platform.
● To understand how you use the Platform, including across your devices.
● To infer additional information about you, such as your age, gender, and
interests.
● To help us detect abuse, fraud, and illegal activity on the Platform.
● To promote the safety and security of the Platform, including by scanning,
analyzing, and reviewing User Content, messages and associated metadata
for violations of our Terms of Service, Community Guidelines, or others
conditions and policies.
● To verify your identity in order to use certain features, such as livestream or
verified accounts, or when you apply for a Pro Account, to ensure that you are
old enough to use the Platform (as required by law), or in other instances
where verification may be required.
● To communicate with you, including to notify you about changes in our
services.
● To announce you as a winner of our contests or promotions if permitted by the
promotion rule, and to send you any applicable prizes.
● To enforce our Terms of Service, Community Guidelines, and other conditions
and policies.
● Consistent with your permissions, to provide you with location-based services,
such as advertising and other personalized content.
● To train and improve our technology, such as our machine learning models
and algorithms.
● To combine all the information we collect or receive about you for any of the
foregoing purposes.
● To facilitate sales, promotion, and purchases of goods and services and to
provide user support.
● For any other purposes disclosed to you at the time we collect your
information or pursuant to your consent.
How We Share Your Information
We are committed to maintaining your trust, and while Soulside does not sell yours
personal information or share your personal information with third parties for
purposes of cross-context behavioral advertising where restricted by applicable law,
we want you to understand when and with whom we may share the information
Collect for business purposes.
Service Providers and Business Partners
We share the categories of personal information listed above with service providers
and business partners to help us perform business operations and for business
purposes, including research, payment processing and transaction fulfillment,
database maintenance, administering contests and special offers, technology
services, deliveries, sending communications, advertising and marketing services,
analytics, measurement, data storage and hosting, disaster recovery, search engine
optimization, and data processing. These service providers and business partners
may include:
● Payment processors and transaction fulfillment providers, who may receive
the Information You Provide, Information From Other Sources, and
Automatically Collected Information but who do not receive your message
data, including, in particular, the following third-party payment
providers/processors: PayPal
(https://www.paypal.com/us/webapps/mpp/ua/privacy-full) and Stripe
(https://stripe.com/en-ie/privacy).
● Customer and technical support providers who may receive the information
You Provide, Information From Other Sources, and Automatically Collected
Information.
● Researchers who may receive the Information You Provide, Information From
Other Sources, and Automatically Collected Information but would not receive
your payment information or message data.
● Advertising, marketing, and analytics vendors who may receive the
Information You Provide, Information From Other Sources, and Automatically
Collected Information but would not receive your payment information or
message data.
In connection with a sale, merger, or other
BusinessTransfer
We may share all of the information we collect in connection with a substantial amount
corporate transaction, such as the sale of a website, a merger, consolidation, asset
sales, or in the unlikely event of bankruptcy.
For legal reasons
We may disclose any of the information we collect to respond to subpoenas, court
orders, legal process, law enforcement requests, legal claims, or government
inquiries, and to protect and defend the rights, interests, safety, and security of the
Platform, our affiliates, users, or the public. We may also share any of the
Information We Collect to enforce any terms applicable to the Platform, to exercise
or defend any legal claims, and comply with any applicable law.
With Your Consent
We may share your information for other purposes pursuant to your consent or at
your direction.
We partner with third-party services (such as Facebook, Instagram, Twitter, and
Google) to offer you a seamless sign-up, log-in, and content-sharing experience. We
may share information about you with these third-party services if you choose to use
these features. For example, the services may receive information about your activity
on the Platform and may notify your connections on the third-party services about
your use of the Platform, in accordance with their privacy policies. If you choose to
allow a third-party service to access your account, we will share certain information
about you with the third party. Depending on the permissions you grant, the third
party may be able to obtain your account information and other information you
choose to provide.
If you choose to engage in public activities on the Platform, you should be aware of that
any information you share may be read, collected, or used by other users. You
should use caution in disclosing personal information while using the Platform. We
are not responsible for the information you choose to submit.
When you make a purchase from a third party on the Platform, including from a
merchant selling products through our shopping features, we share the information
related to the transaction with that third party and their service providers and
transaction fulfillment providers. By making the purchase, you are directing us to
share your information in this way. These entities may use the information shared in
in accordance with their privacy policies.
Your Rights
You may submit a request to know, access, correct or delete the information we have
collected about you at info@soulside.app. You may appeal any decision we have
made about your request by following the instructions in the communication you
receive from us notifying you of our decision. You may also exercise your rights to
know, access, correct, delete, or appealby sending your request to the physical
address provided in the “Contact Us” section below. You can also update your
account information directly through your in-app settings, as well as request a copy
of your Soulside data or request to deactivate or delete your account. Your right to
know includes what personal information we have collected about you, including the
categories of sources from which the personal information is collected, the business
or commercial purpose for collecting or sharing personal information, the categories
of third parties to whom we share the personal information, and the specific pieces of
personal information we have collected about you. We do not discriminate based on this
the exercise of any privacy rights that you might have.
You may be entitled, in accordance with applicable law, to submit a request through
to authorized agent. To designate an authorized agent to exercise choices on your
on behalf, please provide evidence that you have given such agent power of attorney or
that the agent otherwise has valid written authority to submit requests to exercise
rights on your behalf. We will respond to your request consistent with applicable law
and subject to proper verification. We will verify your request by asking you to send it
from the email address associated with your account or to provide information
necessary to verify your account.
The metrics for requests to access, correct, and delete received by Soulside during
the previous calendar year can be found here.
While some of the information that we collect and use may constitute sensitive
personal information, we only process such information in order to provide the
Platform and within other exemptions under applicable law. For example, we may
process your financial information in order to provide you with the goods or services
request from us or your driver's license number in order to verify your identity.
Your Choices
● You may be able to control some of the information we collect through you
device browser settings to refuse or disable cookies. Because each browser
is different, please consult the instructions provided by your browser. Please
note that you may need to take additional steps to refuse or disable certain
types of cookies. In addition, your choice to disable cookies is specific to the
particular browser or device that you are using when you disable Cookies, so
you may need to separately disable cookies for each type of browser or
device. If you choose to refuse, disable, or delete Cookies, some of the
functionality of the Platform may no longer be available to you. Without this
information, we are not able to provide you with all of the requested services.
● You can navigate to "Ads" in your in-app settings to opt-out of targeted
advertising based on personal information about your activity on nonaffiliated
apps and websites.
● You may be able to manage third-party advertising preferences for some
the third parties we work with to serve advertising across the Internet by using
the choices available at
https://www.networkadvertising.org/managing/opt_out.asp and
https://www.aboutads.info/choices.
● Your device may have controls that determine what information we collect.
For example, you can control whether we can collect your mobile advertising
identifier for advertising through settings on your Apple and Android devices.
● You can opt out of marketing or advertising emails by using the “unsubscribe”
link or mechanism noted in marketing or advertising emails.
● Current versions of the app do not collect precise or approximate GPS
information from US users. If you are still using an older version that allowed
for collection of precise or approximate GPS information (last release in
August 2020) and you granted us permission to do so, you can prevent your
device from sharing such information with the Platform at any time through
your device's operating system settings.
● If you have registered for an account, you can access, review, and update
certain personal information that you have provided to us by logging into your
account and using available features and functionalities.
● Some browsers transmit “do-not-track” signals to websites. Because of
Differences in how browsers incorporate and activate this feature, we currently
do not take action in response to these signals.
Data Security and Retention
We use reasonable measures to help protect information from loss, theft, misuse,
unauthorized access, disclosure, alteration, or destruction. You should understand
that no data storage system or transmission of data over the Internet or any other
public network can be guaranteed to be 100 percent secure. Please note that
information collected by third parties may not have the same security protections as
information you submit to us, and we are not responsible for protecting the security
of such information.
We retain information for as long as necessary to provide the Platform and for the
other purposes set out in this Privacy Policy. We also retain information when
necessary to comply with contractual and legal obligations, when we have a
legitimate business interest to do so (such as improving and developing the Platform,
and enhancing its safety, security and stability), and for the exercise or defense of
legal claims.
The retention periods are different depending on different criteria, such as the type of
information and the purposes for which we use the information. For example, when
We process your information such as your profile information to provide you with the
Platform, we keep this information for as long as you have an account. If you violate
our Terms of Service, Community Guidelines, or other conditions or policies, we may
remove your profile immediately, but may keep other information about you to
process the violation.
Soulside may transmit your data to its servers or data centers outside of the United
States for storage and/or processing. Other entities with whom Soulside may share
your data as described may be located outside of the United States.
Children and Teens
The privacy of children is important to us. We provide a separate experience for
Children in the United States, in which we collect and process only limited
information. For information about how we collect, use, share, and otherwise process
the personal information of children, please refer to our Children's Privacy Policy.
The Platform otherwise is not directed at Children. If we become aware of that personal
information has been collected on the Platform from a Child, we will delete this
information and terminate the Child's account. If you believe there is a user who is
below the age of 13, please contact us at: info@soulside.app
Other Rights
Sharing for Direct Marketing Purposes (Shine the
(Light)
If you are a California resident, once a calendar year, you may be entitled to obtain
information about personal information that we shared, if any, with other businesses
for their own direct marketing uses. To submit a request, contact us at:
info@soulside.app
Content Removal for Users Under 18
Users of the Platform who are California residents and are under 18 years of age
may request and obtain removal of User Content they posted by contacting us at:
info@soulside.app . All requests must provide you with a description of the User Content
want removed and information reasonably sufficient to permit us to locate that user
Content. We do not accept California Removal Requests via postal mail, telephone,
or facsimile. We may not be able to respond if you do not provide adequate
information. Please note that your request does not ensure complete or
comprehensive removal of the material. For example, user content that you have
posted may be republished or reposted by another user.
Privacy Policy Updates
We may update this Privacy Policy from time to time. When we update the privacy
Policy, we will notify you by updating the “Last Updated” date at the top of the new
Privacy Policy, posting the new Privacy Policy, or providing any other notice required
by applicable law. We recommend that you review the Privacy Policy each time you
visit the Platform to stay informed of our privacy practices.
Updates to the privacy policy
We may change or update this Privacy Policy from time to time. We will notify you of this
any material changes to this Privacy Policy by posting a notice on the Platform or by
other means. The "Last Updated" date at the top of this Privacy Policy is the effective
date of such changes.
You can contact our data protection officer here:
Project 29 GmbH & Co. KG
Ostengasse 14
93047 Regensburg
Phone: 0941-298693-19
www.projekt29.de