We at Synereo Ltd. (“Company”, “we”, “us”, “our”) respect your privacy. This Privacy Statement (“Statement”) explains the privacy practices for the HyperSpace platform. It also describes the rights and options available to you with respect to your information.
PERSONAL DATA WE COLLECT
To set up your account on HyperSpace we will collect your nickname, email address and cell phone number.
Initial Account Sign-up. To sign up to HyperSpace, we collect your nickname, date of birth and email address. You may optionally provide a profile image.
To activate your account with full features, we will collect from you a selfie image of you and a copy of your ID card, driving license or passport.
Identity Confirmation. If you wish to fully activate your HyperSpace account with full features, we will also ask to collect your cell phone number, a selfie image of you and a copy of your ID card, driving license or passport (with your name, date of birth and photo).
We process the content of posts and comments you upload and user actions you’ve taken.
User Activities. While you are active on HyperSpace, we process the content of posts and comments you upload, the user actions you’ve taken in relation to content on HyperSpace (e.g., reviewing content on HyperSpace, group management actions, reporting inappropriate content).
We collect your settings and preferences on HyperSpace.
Preferences and Settings. We collect your settings and preferences relating to HyperSpace, such as your age restriction preferences, public-viewability preferences and notification settings.
We collect information relating to technical and customer support requests you contact us with.
Support. When you contact us for technical and customer support requests, we collect the information included in your request and in follow-up interactions we have with you.
You are not legally required to provide us your information.
You do not have a legal duty to provide the above information. However, you will not be able to sign up to and use HyperSpace without providing the above information.
We collect your IP address.
Meta Data. When you interact with HyperSpace, we will collect the Internet Protocol (IP) address of the computer you use to visit HyperSpace.
We also collect analytical information about your use of HyperSpace.
Analytics Information. We record and collect aggregated (statistical) analytics information about your user clicks and mouse movements while you interact with HyperSpace.
HOW WE PROCESS AND USE PERSONAL DATA
We process your data for the following purposes: To operate HyperSpace and provide its features
We process your Initial Account Sign-up information, User Activity information and Preferences and Settings information to operate HyperSpace and provide you and all other users with its features and functionality, such as access to content and receiving and providing AMPs (which are HyperSpace’s virtual currency). We process your date of birth only momentarily during registration to confirm that you are over the age of 13.
To confirm your identify and prevent fraud.
We use your Identity Confirmation information and Meta Data to confirm your identify and prevent fraud.
To send you administrative and promotional notifications relating to HyperSpace.
We process your Initial Account Sign-up information, User Activity information and Preferences and Settings information to send you administrative notifications relating to HyperSpace as well as promotional updates relating to HyperSpace. You can control your notification settings and preferences through your account on HyperSpace.
To develop and enhance HyperSpace.
We process your Analytics Information to understand how users interact with HyperSpace so that we can further develop and enhance HyperSpace.
To handle inappropriate content.
We process your Initial Account Sign-up information, User Activity information and Support information to handle incidents of inappropriate content and take action as required in response to such incidents.
To provide user technical or customer support.
We process your Initial Account Sign-up information, User Activity information and Support information to provide you technical or customer support in response to inquiries on these topics.
To determine your profile and activity score which we then use in deciding to give you and other user AMP rewards.
We process your Meta Data, Initial Account Sign-up information and User Activity information to determine your profile as a user and determine a scaled score of the nature and scope of your activities as a user. We use this profile and score in deciding to give you and other users AMP rewards.
WHEN AND YOUR PERSONAL DATA IS SHARED WITH OTHERS
We will not share your information with third-parties, except in the events listed below or when you provide us your explicit and informed consent
We share your information with our service providers helping us operate our business.
We will share your personal information with our service providers who assist us with the internal operations of our marketing emails. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties.
The service providers we use are listed here.
Users can share your posts and comments with others, such as on social media.
HyperSpace users can share public posts or comments that you uploaded and shared with others. Users can share your posts and comments with others by email to recipients of their choosing, or more publicly on social media. This sharing includes the content of your posts or comments, as well as your nickname on HyperSpace.
If you violated the law, we will share your information with competent authorities.
If you violated any applicable law, your information will be shared with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation.
We will share your information if we are legally required.
If we are required to disclose your information by a judicial, governmental or regulatory authority.
SECURITY AND DATA RETENTION
We retain personal data as needed to support HyperSpace and thereafter for compliance and legal purposes.
We implement measures to secure your Information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune to information security risks.
What are cookies?
Cookies are text files, comprised of a small amount of data, that are saved on your computer or another device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.
The information that the cookies maintain is read by the website you visit, during the session of your visit to the website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies).
We use the Cookiebot add-on to provide you more detailed information about the cookies we use (including their origin, purpose and expiration dates). It also enables you to control the use of marketing cookies, preference cookies, and statistics cookies. Click here to access Cookiebot. You can change your mind at any time by enabling or disabling certain cookies or categories of cookies. However, you cannot disable the ‘necessary’ cookies because HyperSpace cannot operate without them. By enabling cookies, you give your consent to collect the data they are intended for.
Necessary. Cookies that are strictly necessary for the functioning of HyperSpace. HyperSpace cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but some parts of HyperSpace may not function properly.
Preferences. Cookies that remember your choices when you use HyperSpace and allow HyperSpace to operate by reflecting your preferences.
Statistics. Cookies that help us understand how you and other users interact with HyperSpace by collecting data that does not directly identify you.
Marketing. Cookies that track your use of HyperSpace and allow us to tailor content, both on and off HyperSpace, that we believe is relevant to you.
ADDITIONAL INFORMATION FOR USERS IN THE EU
Synereo Ltd. is the data controller of your personal data.
Synereo Ltd. is the data controller of the personal data we process about you. Synereo’s address is at:
45 David Bloch Street
Tel Aviv, 6468111
Contacting our European representative.
Our European representative, for the purposes of this Statement, is GDPR-Rep.eu. If you are within the European Economic Area, you may contact our European representative by visiting https://gdpr-rep.eu/q/15255512 or through the following address:
iuro | Dr. Andreas Mätzler
Attorney at Law
1010 Vienna, Austria
Please add the following subject to all correspondence with our EU representative: GDPR-REP ID: 15255512
Legal bases for processing your information.
The legal basis under EU law for processing your information for the purpose of operating HyperSpace and providing its features is the performance of our Term of Use contract with you and our legitimate interests in the proper management and operation of HyperSpace.
The legal basis under EU law for processing your information for the purpose of sending you notifications relating to HyperSpace is our legitimate interests in informing users of administrative issues and encouraging user engagement with HyperSpace.
The legal basis under EU law for processing information to handle inappropriate content on HyperSpace is our legitimate interests in keeping HyperSpace free of offensive and infringing content, our necessity for compliance with legal obligations relating to such content and necessity for protecting the vital interests of other users.
The legal basis under EU law for processing information to provide you technical or customer support is our legitimate interests in assisting our users on issues relating to their use of HyperSpace.
The legal basis under EU law for processing Analytics Information to further develop and enhance HyperSpace is our legitimate interests in fostering and advancing HyperSpace.
The legal basis under EU law for processing your profile as a user and determining your scaled activity score is our legitimate interests in operating HyperSpace’s underlying business model of New Content Economy.
The legal basis for sharing your information with competent authorities and with third parties for the purpose of handling violations is our legitimate interests in enforcing our legal rights.
The legal basis for disclosing your information at the request of a judicial, governmental or regulatory authority is our compliance with legal obligations to which we are subject.
The legal basis for processing your information for the purpose of notifying you or providing you with updates to this Statement is our legal obligation under the GDPR.
Automatic decision making.
We perform automatic decision making in confirming your identity for the purpose of fraud prevention. We do so by using an automated tool that corroborates whether your Initial Account Sign-up information matches your Identify Confirmation information. The tool we use is regularly tested to enhance accuracy and reliability.
You may contact us through the channels listed below to request that we intervene with human involvement to reconsider your identify confirmation if the automated tool in unable to do so.
We perform automatic decisions in determining if and how many AMP rewards to give you and other users. This is done on the basis of your profile and HyperSpace activity score. An explanation of the criteria in this decision-making process is provided here. This automatic decision making is regularly reviewed and tweaked to enhance accuracy, reliability and fairness to all users.
You may contact us through the channels listed below to request that we intervene with human involvement to reconsider your eligibility for AMP rewards if you believe the automatic decision making has made an error.
We will transfer your Information internationally only in accordance with applicable data protection laws.
Information we collect from you will be processed by Synereo in Israel, which is recognized by the European Commission as having adequate protection for personal data.
When we transfer your Information from within Europe to other jurisdictions outside Europe, we will do so by using adequate safeguards determined by the EU Commission.
The EU safeguards for international transfers relating to our service providers are listed here.
You have certain rights to access, update or delete your information, obtain a copy of your Information, withdraw your consent and object or restrict certain data processing activities.
If you are in the EU, you have the following rights under the GDPR:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to Withdraw Consent to processing your personal data, at any time, where the processing is based on consent – such as the processing of marketing cookies. If you do that, we will still process certain information on a legal basis other than consent, as described in this Statement. Withdrawing your consent will not affect the lawfulness of the data processing we carried out based on your consent before such withdrawal.
Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interests. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.
Right to Restrict processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Statement, but you require them to establish, exercise or defend legal claims; or if you object to processing, pending the verification whether our legitimate grounds for processing overrides yours.
Right to be Forgotten. Under certain circumstances, such as when your right to object overrides our legitimate interests, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.
If you wish to exercise any of these rights, contact us at [email protected].
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.
You have a right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
CHANGES TO THIS PRIVACY STATEMENT
If we change this Statement, we will provide you notice of such change through the App.
From time to time, we may change this Statement, in which case we will inform you of the updated Statement by emailing you.
You can contact us at [email protected]
Should you have any inquiries, complaints or suggestions, you may contact us at [email protected]. We will do our best to resolve your issue in a timely manner.
Last Update: December 13, 2018