Privacy Policy

Last updated April 2019

Below you find a summary of our commitment to your privacy. At Soulpicks we take your privacy seriously. Our goal is to be as transparent as possible, towards you, as a user of the Soulpicks app (hereafter: 'App'), on what kind of personal data we collect, for which purpose we collect your data and what your rights are. This Privacy Policy ('Privacy Policy') is intended to be simple to read and to provide a complete explanation of these matters.

1. How do we protect your data

We fully commit to the privacy and security of your data. Our goal is to deliver an excellent App experience while respecting your privacy and while keeping your data both private and secure.

All personal data collected and processed by us, is handled in strict compliance with the European General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'). However, this is not enough according to us. We do the best we can to take every technical and organizational measure possible to protect your data against any accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access or any other unlawful or unauthorized processing.

Please read our security page to understand the extent of the measures we take to protect your data.

2. What kind of personal data do we collect

We collect personal data when you create an account. Additionally, you can choose to enrich your profile data, add experience data to a “Soulpick” or use your location data to add a place to your collection. We then store this information in our database that is protected by the security measures mentioned above.

2.1 Your account data

To sign up, you have to provide the following information:

First and last name, mobile number

2.2 Your profile data (optional)

On your profile page, you can choose to add information, such as:

A profile picture

A short biography

Personal interests

The city in which you live or stay

2.3 Experience data (optional)

In a “Soulpick,” you can choose to add information about your experience, such as:

Comments

Pictures

To upload pictures you have to give the App access to your camera or to the pictures stored on your phone by changing the default setting in the “Settings” of your phone.

2.4 Location data (optional)

To help you quickly build your collection, you can choose to add location data from different sources:

Google Maps, Foursquare and other apps (your saved places)

Notes (a copy-pasted list)

Location data can also be used to show your current location on the map and to filter search results based on your location. If you wish to use this feature, you have to change the default setting in the “Settings” of your phone.

3. For which purpose do we use your data

We use your data to create your account, to complete your profile, to add experience data to your collection, to add places from location data sources, to communicate with you, and to improve your App experience.

3.1 To create and use your account

We use your first name, last name, and mobile number to create an account. To create the account, we send a verification message to your mobile number.

3.2 To complete your profile

In addition to your first and last name, you can complete your profile by adding optional personal data as mentioned above. People who would like to follow you can find your basic profile data (first name, last name and profile picture) within the App.

3.3 To add experience data

For every “Soulpick” you add to your collection, you can add the experience data mentioned above to complete your experience. Only you can see this information.

Your experience data is not shared with other users by default. However, you can change this default setting in the App into ‘shared with my followers’. You can also individually decide for each Soulpick with whom you share it.

3.4 To add places from location data sources

You can use the location data mentioned above to add places to your collection. If you add location data from other apps, we automatically remove this data after you have selected places to add to your collection.

3.5 To communicate with you

The App can send you several notifications, i.e., sounds, symbol-badges or messages. If you wish to receive such notifications you have to change the default setting in the "Settings" of your phone.

3.6 To improve your App experience

We continuously work to improve our software. We collect anonymized data for troubleshooting (e.g., bugs), to prioritize features and to enhance the design and content of our App. We might, for example, collect the most frequently selected categories or the average duration of a page visit.

This information also enables us to personalize your App experience. We do not use the collected data for any other purpose than for our services. All collected data is anonymized so that it can never be used to identify you.

4. How long do we retain your data

We will process and store your data as long as you have a registered account. You are always entitled to withdraw your account and initiate to delete all your data, through your account settings. We shall not retain the personal data any longer than required for the purposes described above or required under the applicable legislation.

5. Your rights with respect to your data

You have the right to access, change, copy or erase your data at any time and to receive any information or help from us in respect thereof. You are also entitled to withdraw your consent and object to our processing of your data at any time.

In case you decide to erase personal data or completely remove your account we process this request as fast as possible. Due to technical reasons, this may take some time, however, always within the time frame required by law. Please be aware that when your personal information is removed, this process is irreversible.

If you have any further questions or remarks concerning our processing of your data, please contact us at support@soulpicks.com.

If you have any complaints about how we process your data or your requests, please contact us at support@soulpicks.com. If that does not solve your complaint, you can always contact the Dutch supervisory authority (www.autoriteitpersoonsgegevens.nl).

6. Sharing personal data with third parties

We will not share your data with any party unless required by law or requested by a court of competent jurisdiction. We will not sell your data to third parties nor will we use your data in any commercial manner.

For our App to operate, we need to provide your data to certain third-party service providers (so-called ‘data processors’) such as Amazon Web Services (AWS) and Mixpanel. These data processors process your data solely on our behalf, and they are only entitled to process the data to perform their services in accordance with our instructions. The data processor guarantees that their processing of the data meets the requirements of the GDPR and ensures the protection of the rights of all data subjects. A data processing agreement between the data processor and us shall always govern the processing of personal data by a data processor.

7. Third party links

Our App contains links to third-party public websites (e.g., the website of a restaurant, bar or museum) and external photographer profiles.

In most cases, a “Soulpick” contains a link to an external website to provide you with relevant information not available within the App. Furthermore, when a “Soulpick” contains a header photo temporarily taken from Google, whenever the person who has taken it is known, it also includes a link to the profile of the photographer.

Please be aware that we are not responsible for the privacy practices of these third-party websites. This Privacy Policy applies solely to the personal information collected and used by our App.

Finally, the App makes use of Google Maps API(s). Your use of Google Maps is subject to the Google Privacy Policy at https://www.google.com/policies/privacy/.

8. Who is responsible for your data

Soulpicks B.V. is the so-called data controller, the responsible party in charge of processing your data.

Our company details are:

Soulpicks B.V.

Rokin 75

1012 KL Amsterdam

The Netherlands

Trade register number: 70628475

You can contact us at any time at support@soulpicks.com.

9. Notification of changes

Over time there will be changes to this Privacy Policy due to App improvements or changing legislation. We shall notify you of these changes within our App as transparently as possible. All Privacy Policy changes will take effect within one month after these in-App notifications. If you don’t agree with the changes, you can withdraw your consent and ask us to erase your data in conformance with this Privacy Policy.

Amsterdam, April 2019