Simi App Privacy Policy

At Simi Studios, your privacy and the security of your personal data are important to us.

Simi is a mobile application by Simi Studios Pte Ltd (“Simi”, “we”, “our” or “us”). Simi is designed for close groups to interact in a safe and private setting.

This Privacy Policy explains our practices on the collection, use, and disclosure of your information (“Personal Data”) in connection with Simi, our website (https://simiapp.co) and other services by us (collectively, “Services”).

We use Personal Data to provide our Services, to communicate about existing and new features with you, and to comply with our terms and applicable laws. We do not sell Personal Data.

Please read this Privacy Policy carefully as you consent and agree to be bound by it while installing, accessing, or using the Services. Your use of the Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy.

We endeavour to implement and maintain the highest standards with regard to privacy and adopt policies in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”).

We may amend this Privacy Policy from time to time by posting the updated policy on our Services platform. When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g. by sending you an email or by displaying a notice on our website. By continuing to use our Services after the changes come into effect, you agree to be bound by the revised policy.

This Privacy Policy may be available in multiple languages. In the event of any dispute arising from its interpretation, the English language version shall prevail.

WHO HAS ACCESS TO YOUR PERSONAL DATA COLLECTED?

The Personal Data controller and processor in respect of the Services is Simi Studios Pte Ltd, a company registered in Singapore with company number 202034393Z, whose registered office is located at 10 Anson Road #16-12 International Plaza, Singapore 079903.

Without prejudice to our Terms of Use, we will not share or open access of your Personal Data to third parties without your consent or notice, unless we believe that such disclosure is necessary to:

  • comply with the law or legal process served on us;
  • protect and defend our lawful rights and property;
  • detect, investigate, prevent and address fraud and other illegal activity, security or technical issues; and
  • protect the personal safety of Simi, our Services users, and/or the public.

In the event of an internal restructuring of our or our affiliates’ businesses or the sale of Simi or any of its assets to a third party, the control and permission granted by you to us in respect of your Personal Data will be transferred to the new owner.

For the avoidance of doubt, we are not responsible for the safety and security of your Personal Data where you have voluntarily shared your Personal Data with third parties to sign up for or use third-party goods or services, whether directly or indirectly through the Services.

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

  1. Account and profile information that you provide when you register for an account on our Services, for example, your name, mobile phone number, email address, date of birth, gender, and profile picture. This is to provide the ability for you to represent yourself to other members of your groups that you created or joined with your contacts. (Collectively, “Account Data”)
  2. Contact list that you grant access to search for and add contacts to your groups or invite them to use our Services. We do not store your contact list.  (Collectively, “Contact Data”)
  3. Content you provide through the use of our Services, for example, photos, messages, and events which you created to share with other members in your groups. We review the contents only if there are user reports indicating a violation of our Terms of Use. (Collectively, “User Content”)
  4. Your usage of our Services such as the actions performed on mood selection, like or comment on other users’ contents, and when you last used our Services. This is so that we may show you your activity statistics in the future. (Collectively, “Usage Data”)
  5. Other members’ usage of our Services that involve you, such as when your contacts add you to a group or send you a virtual gift. (Collectively, “Usage Data”)
  6. Location information that you grant access to when you are using our Services. This is to enable the sharing of location and weather information among group members and to enable some features that are only available to a specific country. (Collectively, “Location Data”)
  7. Device information such as operating system, hardware and software versions, internet protocol (IP) address, browser type and version, time zone setting, data from device settings, and data from cookies stored on your device which may include essential, functional, and performance/analytical cookies. (Collectively, “Technical Data”)
  8. Communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or questionnaire that we send you. (Collectively, “Preference Data”)
  9. Support information that you provide when you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots. (Collectively, “Support Data”)

HOW DO WE USE THE PERSONAL DATA WE COLLECT?

Provide our Services, including to:

  • Invite you to use our Services;
  • Operate our Services, which include allowing you to share your content with your contacts;
  • Maintain and improve the Services and the Services’ features;
  • Create and maintain your account;
  • Send you push-notifications (only if you grant access);
  • Provide support for the Services and respond to your requests, questions, and feedback.

Location-related information. We use location-related information to provide, personalize and improve our Services for you and others.

Product research and development. We use the information we collect to develop, test, and improve our Services, including by conducting surveys and research, testing and troubleshooting new features.

Promote safety, integrity, and security. We use the information we collect to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences and maintain the integrity of our Services.

Communicate with you. We may use the information we collect to send you marketing communications as permitted by law, communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us. You may opt-out of our email marketing communications by updating your preferences within your account on our Services. Please note that we may still send you transactional or important emails regarding your account or use of our Services even after you opt-out of direct marketing.

Support and Maintenance. We may use third-party analytics services (such as those provided by Apple App Store and Google Play Store) to automatically log certain information about your mobile device and how you interact with our Services. The information collected is used to troubleshoot and prevent errors, perform data analysis, and develop new features.

Enforce our terms and policies. In some cases, we use the information we collect for legal purposes. For example, when unlawful content is posted on our Services, we may need to enforce our Terms of Use and other policies. We may also use or share your information to cooperate with law enforcement requests or comply with our legal obligations.

HOW DO WE SHARE INFORMATION?

We may share information we collect about you in the following ways:

With other Services users. We may share with other Services users (they are your contacts that you chose to add to your groups) the information such as your name or username, your profile information, and the content you post or send.

With third parties. We may share with service providers who perform services on our behalf or help us operate our Services (such as hosting, analytics, SMS delivery) for purposes such as to measure and optimize performance and delivery of functionality of our Services. We may also share information on an aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our Services. Our Services may contain third-party content and integrations. Examples include links to third-party websites over which we have no control or features provided by third-party such as plug-in and games. Through these integrations, you may be providing information to the third-party service provider, and thus your information will be governed by their policies. We encourage you to review the privacy policies of every third-party service that you use through or on our Services.

With law enforcers. We may collect, use, preserve and share your information with the government or law enforcement authorities if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law, regulations, legal process or government requests; (b) enforce our Terms of Use and other policies; (c) detect, investigate, prevent and address fraud or other illegal activity, security or technical issues; or (d) protect the rights, property, and safety of our Services users, the Services, Simi or others.

With business transferees. If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such a transaction takes place and inform you of any choices you may have regarding your information.

HOW DO WE PROCESS AND STORE YOUR PERSONAL DATA?

Simi is based in Singapore. The Personal Data that we collect from you will be transferred to, stored at, or processed in Singapore and other countries globally where we have or use facilities, service providers, or partners, regardless of where you use our Services. We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate technical, administrative, and organizational security measures. For example, Simi operates on a secure platform certified in ISO/IEC 27001 security standards. Data in transit is encrypted using HTTPS protocol. Data at rest is encrypted using 256-bit Advanced Encryption Standard and stored in secure servers. Although we work to protect the security of your account and your Personal Data, please be aware that no method of transmitting data over the Internet or storing data is fully secure or error-free. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your information or content.

We retain the information we collect from you until you delete your Services account or for the length of time needed to fulfill any purposes and usage described in this Privacy Policy or to comply with applicable laws and regulations.

By using our Services, you agree to how and where we collect, use, process, store, and transfer your information as described in this Privacy Policy. You acknowledge that the laws, regulations, and standards of the country in which your information is transferred to, stored at, or processed may be different from those of your own country.

MANAGING YOUR INFORMATION

If you would like to manage, change, limit or delete your information, we allow you to do so through the following tools:

Services settings. You can change your Services settings to manage certain information available to other users. You can manage your profile data, your groups, and you can choose to leave a group that you previously joined.

Changing your profile information. You can change your profile name, profile picture and other status from the Profile page at any time. To change your email and mobile number, please contact us at [email protected]

Deleting Your Products Account. You may delete your account at any time using the “Delete Account” option from the Profile page. When you delete your account, your undelivered messages are deleted from our servers as well as any of your other information we no longer need to operate and provide our Services. Be mindful that if you only delete (uninstall) our Services from your device without deleting your account, your information may still be stored with us. Please remember that when you delete your account, it does not affect the information other users already possess relating to you, such as their copy of the messages you sent them.

PERSONAL DATA OF CHILDREN

As noted in our Terms of Use, we do not knowingly collect Personal Data from children under 13. If we become aware that a child under 13 has provided us with personal information without the consent of the child’s parent or guardian as required by law, we will take steps to delete such information. If you believe that we have mistakenly or unintentionally collected information from an individual under 13, please contact us at [email protected]

USERS IN THE EUROPEAN UNION

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

  1. The right to be informed – You have the right to be informed of what we do with your personal information.
  2. The right to access – You can request a copy of your Personal Data. You can also access certain of your Personal Data by logging on to your account.
  3. The right to rectification – You can request us to correct any inaccuracy or error in any personal information we hold about you. You may also correct it on your own as described in the “Managing Your Information” section above.
  4. The right to erasure – You have the right to request us to delete your Personal Data (please note that we may not always be able to comply with your request to erasure for record-keeping purposes, to complete transactions, or to comply with our legal obligations). You may also delete your posted contents (such as photos) or your account as described in the “Managing Your Information” section above.
  5. The right to restrict processing – You can request us to restrict further processing of your personal data.
  6. The right to object to processing – You can object to our use of your information. With certain types of data, we have provided you with the ability to simply delete it if you do not want us processing it anymore. In other cases, we have given you the ability to stop the use of your data (please refer to the “Managing Your Information” section above).
  7. The right to data portability – You can request to transfer the data that we have collected to another organization, or directly to you, where technically feasible.

If you make a legitimate request, we aim to respond to you within one month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests. Any request will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

If you would like to exercise any of these rights, please contact us at our email: [email protected] For the protection of all our users’ interests, please note that we will need to take all reasonable steps to verify your identity prior to processing your requests or releasing any Personal Data requested to you.

Bases for Using Your Information. Your country only allows us to use your personal information when certain conditions apply. These conditions are called “legal bases” and, at Simi, we typically rely on one of four:

  1. Contractual Necessity – to provide you with the Services in accordance with our Terms of Use. 
  2. Legitimate Interest– where it is necessary for our legitimate business purposes, your interest, or the interests of a third party. 
  3. Consent – In some cases, we will ask for consent to use your information for specific purposes. If we do, we will make sure you can revoke your consent in our services or through your device permissions. Even if we are not relying on consent to use your information, we may ask you for permission to access data like contacts and location.
  4. Legal Obligation – We may be required to use your personal information to comply with the law, like when we respond to a valid legal process or need to take action to protect our users.

Summary of Data Processing Purposes

Purpose of processingCategory of Personal DataLegal basis
To register you as a user on our ServicesAccount DataContractual Necessity
To enable you to use our ServicesAccount Data, Contact Data, Technical Data, User Content, Support Data, Location DataContractual Necessity
To respond to your inquiriesAccount Data, Support DataContractual Necessity
To notify you about changes to our Services or termsAccount DataContractual Necessity
To administer and maintain safety and security of our ServicesTechnical Data, Support DataContractual Necessity Legal Obligation
To study usage of our ServicesSupport Data, Technical Data, Usage Data, Location DataLegitimate Interest to improve our Services
To gather feedback on our ServicesAccount DataLegitimate Interest to improve our Services
To provide information relating to our Services that may be of interest to youAccount Data, Preference Data, Location DataConsent, which you may withdraw any time

HOW TO CONTACT US

Please contact us at the following:

Address              : Data Protection Officer, Simi Studios Pte Ltd, 10 Anson Road #16-12, International Plaza, Singapore 079903

Email                   : [email protected]

When contacting us, we would appreciate it if you could (1) provide sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to your request appropriately. You may also direct any complaint about the Services to our Data Protection Officer through the contact details above or file a complaint with the national authority.

If you have any questions about our Privacy Policy, please get in touch with us through the contact details above.

Last updated: 8 August 2021