Privacy Policy (SoFriendly) PRIVACY POLICY (SoFriendly) respects your privacy and has developed this privacy policy (the “Privacy Policy”) to present our commitment to protecting your privacy and to explain how we collect, use, and share Personal Data from or about you in connection with your use of the (SoFriendly) Service (the “Data”).

We encourage you to read this Privacy Policy carefully when using the (SoFriendly) Service or transacting business with us.

If you reside in a country that is part of the European Economic Area (including in the United Kingdom), or Switzerland (collectively referred to as “EEA”), any reference to " (SoFriendly)", "we", "us", or “our” in this Privacy Policy will always refer to “TelecomPay Communication Limited” whose details are provided here.

If you reside in a country that is not part of the European Economic Area or Switzerland, any reference to “ (SoFriendly)”, “we”, “us”, or “our” in this Privacy Policy will always refer to “TelecomPay Communication Limited” whose details are provided here.



The terms “ (SoFriendly) Service” or “Service” refer to the following: the (SoFriendly) principal website accessible at and at any of its local versions (the “ (SoFriendly) Site”), the (SoFriendly) secondary websites (“Secondary Sites”), the (SoFriendly) video player when it is embedded onto any website (the "Video Player"), the (SoFriendly) apps and web-apps (the “ (SoFriendly) Applications”) as accessible via any current or future device capable of distributing the (SoFriendly) Site and/or the Video Player, together with any (SoFriendly) products, content, channels, software, data feeds, services and functionality.

In connection with its main activity as a content hosting platform, (SoFriendly) operates Secondary Sites addressed to professionals in the advertising industry, such as software developers wanting to contribute to or use the (SoFriendly) APIs, content right holders interested in the (SoFriendly)’s Partner Program, advertisers, media agencies and various actors of the marketing sector who wish to learn more about our offering. All of the Secondary Sites can be accessed from the (SoFriendly) Site but, due to the particularity of their audience, may be subject to distinct terms of use. The use of their visitors’ Data is limited by the particular purpose of these sites and is further explained in the dedicated Section 9 of the present Privacy Policy.

The term “Commercial Partner” refers to entities (SoFriendly) may cooperate with while carrying out its Services. In particular, Commercial Partners may include content editors, advertisers, media agencies and other actors of the on-line marketing sector. (SoFriendly) belongs to the TelecomPay Communication Limited. Some of the Commercial Partners may also be a part of the TelecomPay Communication Limited and thus will also be (SoFriendly)’s affiliates.


The term “Content” refers to videos available on the Service.

The terms “Personal Data,” “Data Controller,” “Joint Controller,” “Data Processor” and “Processing” used in the present Privacy Policy shall have the same meaning as defined in the General Data Protection Regulation (“GDPR”), or unless, otherwise stated herein, under applicable local data protection laws. Personal Data processed by (SoFriendly) is referred to as “Data”.

We encourage you to read this Privacy Policy carefully when using the (SoFriendly) Service or transacting business with us.


    • 1. (SoFriendly)’s Role in Processing of Personal Data

Certain Data from or about you may be collected or otherwise processed when you use the (SoFriendly) Service, regardless of whether you do so as a Viewer, Visitor, User, or member of the “Partner Program” (as defined in the (SoFriendly) Terms of Use).

If you reside in a country that is part of the European Economic Area, the GDPR is applicable to the collection of your Personal Data. If you reside outside of the EEA, local laws are applicable to such collection.

Note that the laws applicable to further processing of your Personal Data depend on your country of residency and that of an entity that uses your Personal Data.

When (SoFriendly) (or its Data Processors) process your Data, we do so for the purposes that we have defined and explained to you in the present Privacy Policy and, if applicable laws require so, subject to existence of a valid legal basis justifying such Processing (e.g. your consent, legitimate interest, contract execution, legal obligation). In such cases, (SoFriendly) acts in its role of a Data Controller. We may hire some service providers to help us implement certain aspects of your Data Processing. In doing so, these service providers act on our behalf following our instructions and thus are considered our Data Processors.

In some cases, (SoFriendly) and its Commercial Partners may process your Personal Data together for joint purposes. Under these circumstances, (SoFriendly) and these Commercial Partners act in their role of Joint Controllers.

Your Personal Data may also be processed by our Commercial Partners (or by their respective Data Processors) for purposes that each of them defines independently. It is the Commercial Partners who are Data Controllers for such Processing of your Personal Data; the role of (SoFriendly) is limited to the collection of consent on Commercial Partners’ behalf (if applicable), transmission of collected consent to such Commercial Partners and providing you with access to their respective privacy policies and consent management mechanisms. (SoFriendly) may also participate in implementation of some Personal Data Processing operations carried out by our Commercial Partners. In such cases, (SoFriendly) acts in its role of a Data Processor while our Commercial Partners remain Data Controllers.

    • 2. Legal Basis for Processing of Personal Data

The GDPR provides several situations upon which (SoFriendly) can rely for Processing of Personal Data, namely consent, contractual necessity, compliance with a legal obligation, vital interests of data subjects, public interest or legitimate interest. Similarly, applicable laws may provide other or similar legal bases, as explained further below in the country specific sections.

When Processing of your Personal Data requires your consent, we ask you to communicate your consent either via a positive action (e.g. by activating “Accept” button on our Site, Secondary Site or Video Player) or via an explicit decision for each of the purposes your consent is being collected for, in accordance with applicable laws.

You can always choose not to consent to Processing of some of your Data, withdraw your consent, or oppose such Processing (unless the applicable laws authorize or require us not to take into account such decision) as further explained herein. However, this may limit your ability to take full advantage of the many features we offer, including features that are needed for our Service to operate as it is intended to and, consequently, seriously deteriorate your user experience. If you do not agree to the collection and use of Data needed for our Service to operate at its optimal capacities, we strongly advise you not to use (SoFriendly) Service as we will not be capable of providing you with the high quality service you may expect from us.


    • 3. Transfer of Data

The Data collected by us through our Service may be sent to and stored on servers located in the United States, France, and other countries around the world.

We ensure that legally required, appropriate contractual or other mechanisms are present prior to transfers of Data outside of the EEA.


We may collect Personal Data that can identify you directly, such as your name and email address, and other information that does not identify you directly. This Section explains what Personal Data we collect and how we collect such information.

    • 1. Categories of Data We Collect

        • 1.1 Data You Provide to Us

We collect Personal Data you provide to us when you interact with the (SoFriendly) Service, including when you sign up for an account, upload Content, create a playlist or share a playlist with others. For instance, when you register to use the (SoFriendly) Service, we may collect your name, email address, birth date, gender, and other similar information. If you are a member of the (SoFriendly) Partner Program, (SoFriendly) may also collect your payment information, such as your address, bank account details and authentication information, as well as billing, shipping and contact details. Note that we do not collect your credit card details. In addition, (SoFriendly) may collect information you provide to us when you respond to surveys, set your preferences on the (SoFriendly) Service, directly contact (SoFriendly) through the (SoFriendly) Help Center or by other means, or agree to participate in promotions that (SoFriendly) may offer from time to time. (SoFriendly) also allows multiple profiles to be set up under one account, so we may collect information you provide to us if you create such profiles.

    • 1.2 Usage and Log Data

We collect information when you use the (SoFriendly) Service or view (SoFriendly) ads outside of the (SoFriendly) Service. We may also collect information from or about the computers, phones, tablets, or other devices where you install (SoFriendly) Applications or otherwise access the (SoFriendly) Service, depending on the permissions you have granted. Examples of this information may include your IP address, device ID number, settings of the browser and software you use (such as type and version of an operating system or its language settings), activity on the (SoFriendly) Service including information about the videos you watch on the Service (e.g. video titles and categories), about the ads you are being shown and your interaction with them, the frequency and duration of your activities, page views, referral URLs, network state, and carrier information.

    • 1.3 Account and Profile Data from Third-Party Services

If you choose to log-in, access or otherwise connect to the (SoFriendly) Service or contact (SoFriendly) through a third-party service (e.g. Facebook), such method being completely optional and subject to your exclusive decision, we may, in order to execute your choice of a log-in or contact method, collect your user ID and user name associated with that third-party service as well as any other information you make public using that service. We may also collect information you have authorized the third-party service to share with us (such as, for example, your user ID, billing information, public profile information, email address, birthday, and profile data).

    • 1.4 Third-Party Data

We may, if you authorized such third parties to share such information with us or if we believe that such sharing is in conformity with the applicable laws, receive from them or share with them information about you originating from other sources, such as data aggregators, public databases, and our Commercial Partners, be it affiliated or unaffiliated entities. Shared data (whether identified, pseudonymized or anonymous and whether collected online or offline) may include information about your interests, demographic data, purchasing behavior, and your online activities (such as websites you have visited and/or advertisements you have viewed).

We may combine the shared information with the information we collect from or about you and use it in the manner described in Section 3 of the Privacy Policy or as otherwise permitted by law.

    • 2. How the Data Is Collected

Like many online services, we use, directly or via our subcontractors, various technologies to collect usage data and store your user settings. The Data thus collected helps us propose, protect and improve the (SoFriendly) Service and to personalize your user experience by adapting the Content and advertising to your taste.

Despite a variety of the actual measures deployed, the various technologies used to collect data are commonly referred to as “cookies” and their use is regulated by “cookie laws.” Whenever the applicable laws subject the use of cookies to user consent, (SoFriendly) asks for your consent prior to their use.

A “cookie” is a small data file that is transferred to your computer’s hard disk. A cookie life is limited to its purpose and does not, in general, exceed 13 months. A cookie expires upon the end of its validity period. A cookie may be deleted before the end of its validity period if you or the technologies you use (e.g. your operating system) do so. The different categories of cookies and assimilated technologies we use are further described below.

    • - Cookies and Local Storage

We may use both session cookies and persistent cookies to offer you a high quality Service, better understand how you interact with the (SoFriendly) Service or with marketing material advertising the (SoFriendly) Service outside of our Service; to monitor aggregate usage by our users and web traffic routing on the (SoFriendly) Service; to customize Content and advertising; to respect the rights of the Content rights holders or that of advertisers and to be in conformity with obligations imposed by applicable laws. We may create a unique device or user ID (“Service ID”) for you and store it in a cookie so we can customize your experience based on your preferences. These uses allow us to create a better experience for you on the (SoFriendly) Service.

We may collect information through other kinds of local storage (also referred to as "Flash cookies") and HTML5 local storage, including in connection with features such as volume/mute settings for the Video Player. These technologies are sometimes referred to as "browser cookies" even though they may be stored in different parts of your computer.

Most Internet browsers automatically accept cookies. By changing your browser settings, you can instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. For further information on disabling cookies or deleting information contained in cookies in general, please click here. Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the (SoFriendly) Service, including the Video Player. For example, we may not be able to store your preferences (such as the language to be used by the Service) or login information (such as keeping your connection session active thus allowing you to be automatically recognized by the Services when you repeatedly access (SoFriendly) Service on the same device) or customize the Content and advertising to your online viewing habits.

    • - Web Beacons, Pixels and other Trackers

In addition to cookies, we may use other similar technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails. These technologies are mainly used to learn whether you have viewed a particular web page, ad, or email message; and determine other usage details including the time and date on which you viewed Content, the IP address of your computer, and the URL of the web page from which the Content was viewed.

    • - Mobile Device Identifiers and Software Development Kits ("SDKs")

We may use or work with third parties, including our Commercial Partners and service providers, who use mobile SDKs to collect information such as advertising identifiers (e.g., "ad-ID" or "IDFA") and information related to how mobile devices interact with the (SoFriendly) Service. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented (a mobile SDK is a mobile app version of a pixel tag or beacon, described above). For instance, we may use this technology to analyze how you interact with Content and advertisements and to enable analytics or other features through mobile devices.

The uses of these various technologies, notably in connection with advertising on the (SoFriendly) Service, are further explained in Section 3 below.

To learn more about our cookie management rules we invite you to read our Cookie Policy. You may, at any time, manage your cookie settings and chose the purposes for which you consent to or refuse use of the cookies by accessing the “Manage Cookies” section available on our Service.


    • 1. Purposes for which Data is Processed by (SoFriendly)

        • 1.1. General

We receive or collect Data, either directly or via our service providers, because we are passionate about creating an engaging and relevant experience for our users, and in order to ensure that the rights of Content right holders and advertisers are respected. We may also share some of your data with (SoFriendly)’s affiliated company (TelecomPay Communication LImited) or with other Commercial Partners to better understand what you may be interested in.

We use all of the legitimately collected or received information to help us provide and support the (SoFriendly) Service with a first-class user experience that is adapted to each user’s tastes, as varied as they may be. The way we actually use the Data about you depends on how you use the (SoFriendly) Service.

    • 1.2. Purposes for which Data is Processed (SoFriendly) may process the Data for the following purposes :

    • - Provide, Improve and Develop the (SoFriendly) Service. We are able to deliver the Service, personalize the Content and advertisements, evaluate the quality of our platform and the Content and make customized recommendations for you by using Data collected on our Service. We analyze that Data to understand how you use and interact with the (SoFriendly) Service and discover the things you’re interested in on and off our Service and ultimately provide you with the best user experience we can offer. For example, we collect your authentication data to allow you to connect to your account, and we collect information on your language setting preferences to provide you with the (SoFriendly) Service in the language of your choice. We may conduct surveys and research, test features in development and analyze the information that we have in order to evaluate and improve our existing products and services, develop new offerings or features and conduct maintenance and troubleshooting activities.

    • Communicate with You. We may use your Data to send you marketing communications, communicate with you about the (SoFriendly) Service and update you about our policies and terms. We also may use your information to respond to you when you contact us, or for any other purpose that is disclosed to you at the time we collect the Data or that is related to a request made by you or related to you. To learn about opting out of promotional communications, please see the information we have provided in Section 9 below (“Your Rights & Opting-Out”).

    • Show and Adapt Ads. (SoFriendly) offers its users the opportunity to watch numerous videos without charging any fee in return. Such free of charge service can only be possible thanks to the presence of advertisements. We may use Data we have, including information received from our Commercial Partners, to evaluate and improve our advertising and analytics systems so that the ads shown to you on and off our Services are customized and of real interest to you. We also use Data to limit the quantity of advertisements you are shown on our Service to allow you to fully enjoy the Content. By processing some of your Data we also measure the effectiveness and reach of ads and services. Your Data may be shared with our Commercial Partners to inform them about your decision whether or not to allow processing of your Personal Data and, if you agreed, to allow them to estimate whether the products or service for which they run advertising campaigns may be of interest to you. To learn about opting out of interest-based or online behavioral advertising, please see the information we have provided in Section 8 below ("Your Rights & Opting-Out") or exercise your choices via (SoFriendly)’s “ Manage Cookies” section available on our Service.

    • Pay You. If you are a member of the (SoFriendly) Partner Program, we use your billing information, such as your billing address or payment methods details, to proceed with payment of sums generated under our Partner Program monetization features. If you choose a third-party payment method, we will communicate to the payment service provider of your choice all information necessary to process due payments and may receive from such payment service provider the receiving account details and related payment confirmations. The exact information communicated or received depend on the payment service provider chosen, the payable amounts and then-current requirements of laws and regulations applicable to financial transactions. Note that we do not use or otherwise access your credit card information.

    • Your Geographic Location. We may collect your device’s location data (limited to the city level only). This information not only allows us to serve you Content related to your local area, such as local news and sports videos, but enables us to ensure the respect of Content geo-restrictions imposed by the Content right holders. This Data may also be used to tailor advertising to you based on your location by, for example, not showing you ads for services unavailable at your location.

    • Elaborate Aggregated or Anonymized Statistics. We may “de-identify” information about you and/or other users, which means that the Data is modified (anonymized or aggregated with other information) so it no longer personally identifies you. We may then use this “de-identified” information for any legitimate internal and external business purpose, including for research and analysis of the (SoFriendly) Service, improving our capacity to deliver customized advertisements, and for promoting our Service to future users, Commercial Partners and other business partners.

    • Ensure Safety and Security of (SoFriendly) Service and its Conformity with Applicable Laws. We may use the Data to ensure the security of our Service and anti-fraud protection. Our dedicated engineering teams do so by using automated procedures and advances technologies such as data encryption and machine learning. Consequently, your Data may be processed as part of investigation of suspicious account activities or violations of our legal terms and policies. In conformity with our legal obligations, (SoFriendly) maintains connections logs linked to each user’s account activities and communicates them, if requested to do so pursuant to applicable legal procedures, to duly authorized public authorities.

    • 2. Purposes for which Data is Processed by our Commercial Partners

When you watch Content or ads on the (SoFriendly) Service our Commercial Partners may process, either directly or via their respective subcontractors, information about you and your use of our Service. They may use this information, including in combination with other data they have access to, in order to adapt content and ads that may be shown to you on our and on third parties’ services. While doing so, our Commercial Partners process your Personal Data in their capacity as Data Controllers and follow privacy policies that are their own.

Your Data may be disclosed to or shared with our Commercial Partners. In particular, we and our affiliated companies. may share the information we have about you. We do so for a common purpose - in order to learn more about your tastes and offer you more personalized services, products and ads

When disclosed Data is used by a Commercial Partner for its own purposes, it is that Commercial Partner who is a Data Controller for the Processing it undertakes. (SoFriendly) works with a large number of Commercial Partners. The list of (SoFriendly) Comercial Partners is published on our Service and may be consulted at all times from within the “Manage Cookies” section. Note that it does not mean that when you watch a video on our Service all of these Commercial Partners process your Personal Data. Only the Commercial Partners (or their technical service providers) involved in posting the ads shown to you or publishing Content that you watch on (SoFriendly) Service process your data. The identity of our Commercial Partners who actually process your data depends on the Content and ads you watch on our Service.

As a Data Controller, each Commercial Partner determines the purpose for which it wishes to process your Personal Data. These purposes may include the development, improvement and delivery of their services, audience and service analytics, personalization and adaptation to your centers of interest of their content, commercial offerings and ads, whether on or outside of the (SoFriendly) Service, conformity with their respective contractual and legal obligations, such as, for example, geographic restrictions of their content exploitation rights, calculation of applicable fees or anti-fraud measures.

When our Commercial Partners’ collection (via the use of cookies or access to you your device) or processing of your Personal Data depends on your consent, (SoFriendly) does ask you for such consent on behalf of our Commercial Partners. Consequently, you may, at all times, manage your consent and indicate the purposes you choose to consent or not to consent to by exercising your choice on the “Manage Cookies” section available on our Service. You may also exercise your right directly by following a link to each of the Commercial Partners’ respective privacy policies as indicated within the Commercial Partners List.

Note that refusing the use of your Personal Data for ad-targeting purposes will not block advertisements. You will still see ads, but they will be less pertinent to your interests.

If you wish to learn more about the purposes for which our Commercial Partners process your Personal Data and the legal basis such processing is based on, we advise you to read their respective privacy policies accessible via links listed within the Commercial Partners List. For reasons inherent to the dynamic character of the online activities, this list of (SoFriendly) Commercial Partners may evolve and is subject to changes. The list will be updated periodically, and we invite you to consult it regularly for the most up-to-date information.


We may share personally identifiable or non-personally identifiable information collected from or about you with third parties, as explained further below (“Data Recipients”). We require such Data Recipients to adhere to strict confidentiality obligations in a way that is consistent with this Privacy Policy and the agreements that we may enter into with them.

    • 1. Social Networking and Single Sign-On Services

When you choose to share information with social networking services or single sign-on services about your activities on the (SoFriendly) Service, such as videos you watched or “liked” on (SoFriendly) Service, such information about you and your activities is shared with that social network or single sign-on service.

Sharing with Facebook or Google. If you connect to (SoFriendly) through your Facebook or Google accounts you may choose to share information about your activities on the (SoFriendly) Service with Facebook or Google and their users, by, for example, publishing on Facebook or Google information about the videos you watch on (SoFriendly). Furthermore, if you visit (SoFriendly) while logged-in to Facebook or Google, then those entities may record your browser details and combine technical information from your web browser with other information that each of them already knows about you. Your decision to share information about your activities on the (SoFriendly) Service within your Facebook or Google profile may result in (SoFriendly) sending relevant information about you to Facebook or Google. Facebook or Google may then make that information visible to their respective users in accordance with applicable law, their own data and privacy policies, and your Facebook or Google privacy settings. We recommend you familiarize yourself with Facebook’s and Google’s respective data and privacy policies and available account privacy controls. We remind you that (SoFriendly) is independent from these third-party companies and that any privacy settings you might have chosen on the (SoFriendly) Service are not applicable on Facebook, Google or any other social network account.

    • 2. Commercial Partners

We work with a number of Commercial Partners who help us offer and improve the (SoFriendly) Service. Such Commercial Partners include, for example, our Content programmers, distributors, and other actors of the digital industry. We may disclose information collected from or about you to such Commercial Partners (or their authorized service providers) when we are legally authorized to do so, but such disclosure is always accompanied by appropriate technical, organizational or contractual measures aimed at ensuring the integrity and security of your information (e.g., aggregation, anonymization, etc.).

In particular, we may share information, generally in the aggregated, encrypted or anonymized form, about you with advertisers and advertising-related service providers. Some Data needs to be shared for technical reasons (e.g., to deliver advertising videos on your screen). Some Data is shared in order to make ads relevant and interesting to you or measure and improve the effectiveness of advertising campaigns. This information includes Data on your digital identifiers, devices used or online activities in relation to your use of the (SoFriendly) Service, such as the websites you have visited and advertisements you have viewed. For example, we may tell an advertiser how its ads performed, or how many people viewed its ads or installed an app after seeing an ad, or provide non-personally identifying demographic information (such as a female between 25 and 30 years of age, living in New York) to these advertisers to help them understand their audience or customers, but only after the advertiser has agreed to abide by strict confidentiality obligations. Note that we do not share directly identifiable information about you (such as your email address) with advertisers and advertising-related service providers.

    • 3. Service Providers

Like most companies, we contract third parties to provide specialized services for us. We may share some of your Data with our service providers who provide us with specialized technical solutions, who are billing facilitators (e.g. PayPal or Payoneer), or who help us analyze and process data (e.g. provide analytic software helping us to improve ads relevancy), mange user accounts, host our websites and content, provide customer support, marketing tools (emails, on-line communication and letters) or otherwise assist us with provisions of the (SoFriendly) Service.

Our Service Providers commit to confidentiality obligations in conformity with the present Privacy Policy and contracts we sign with them.

    • 4. Audience Measurement Providers

Our Commercial Partners, such as content providers and advertisers, seek to measure the performance of their videos across many platforms, including the (SoFriendly) Service. Accordingly, (SoFriendly) may use and permit the use on its Service of independent, industry-standard, third-party measurement software (e.g. Nielsen or comScore) that enables us or our Business Partners to include your video views in our or their measurement statistics. We may also share our own usage statistics, in anonymized or aggregated form, with these Business Partners.

To learn more about your choices with respect to audience measurement software, please see the information we have provided in Section 9 ("Your Rights & Opting-Out").

    • 5. Public Authorities and Legal Counsel

In some instances, we may be required to disclose information from or about you to public authorities or legal counsel without providing you with notice or giving you the opportunity to consent. We may disclose your information in good-faith to protect the legal rights of (SoFriendly), our affiliates or Commercial Partners, and each of our respective equity holders, directors, officers, employees, agents, and business partners; to protect the safety and security of our users of the or of third parties; to enforce our Terms of Use; to protect against fraud; for risk management purposes; and to comply with or respond to the law, a legal process, or a request for cooperation by a government entity. However, it is (SoFriendly)’s policy, whenever reasonably possible and legally permissible, to promptly notify you upon receipt of a subpoena or court order requesting your Data and to not produce your Data until after receipt of such subpoena or court order, so that you will have adequate opportunity to initiate appropriate legal proceedings.

Furthermore, if you notify us that you believe your legal rights have been violated by (SoFriendly) or another user of the (SoFriendly) Service, we may provide the Data that you provide to us to others to the extent that we believe it is necessary to evaluate and respond to your complaint.

    • 6. Third Parties in Connection with Certain Transactions

If we sell all or part of our business, make a transfer of assets, or are otherwise involved in a change-of-control transaction, or in the event of bankruptcy, we may transfer information from or about you to one or more third parties as part of the transaction, including as part of the due diligence process. Please note that in such a case your Data would be shared only as an integral part of the (SoFriendly) Service and not sold or transferred separately from the Service to third parties.

    • 7. Parties You Consented or When You Otherwise Choose to Share Your Data

In addition to the sharing described in this Privacy Policy, we may share any information from or about you with any party when we have your consent or when you otherwise choose to share such information. Also, certain functions within the (SoFriendly) Service may give you the option to share information about your (SoFriendly) activities, for example, by email, text message, social networking, or other sharing function.


    • 1. Data Security

The security of your Data is important to us. Our goal is to make you feel confident and safe when using the (SoFriendly) Service.

We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to only those (SoFriendly) employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission, and firewalls to help prevent unauthorized persons from gaining access to your Personal Data. We also use techniques such as data aggregation to render it more difficult to link and trace information to you.

Despite these efforts, there is always a possibility that a breach in data transmission or storage may occur. We want you to feel confident in our security when using the (SoFriendly) Service, but we cannot guarantee the absolute security of Data at all times. We advise you to exercise caution and, in particular, to use a unique password for your (SoFriendly) account, i.e. a password that you do not use for any other service you have an account with (which could prevent, in the event your (SoFriendly) password confidentiality is breached, unauthorized access to these other accounts), to change your password if you suspect its fraudulent use and contact us if you notice any suspicious activities on your (SoFriendly) account.

    • 2. Account Access

If you have an online account with us, your Personal Data can be reviewed online from within your account settings. You can also update that information either via the account settings or by contacting us (see Section 10.6 “Contact Us” for more details).

Your account is unique to you and protected by a user-generated password. We advise you to choose a unique and complex password, not to disclose it to third parties, and change it if you have any doubts as to its confidentiality. Do not hesitate to contact us if you observe any suspicious activity on your account.

Please note that if you allow others to use your account (including by authorizing others to set up profiles within your account), they may be able to view information about your account (e.g. your email address) or any of the profiles created within your account (e.g. videos you have viewed). You should exercise caution while handling and disclosing your Personal Data on our Service and avoid sending it through insecure email. Please refer to the Federal Trade Commission’s website at for further information on how to protect yourself from identity theft.


Data is stored electronically on (SoFriendly)’s servers or with our cloud service providers and is kept only as long as necessary for the purposes set out in the present Privacy Policy or as otherwise required by applicable laws.

We have a legal obligation to store some Data, such as information associated with the identity of an account holder (retained for a period of one year following the deletion of an account) or invoicing details. If you ask us to delete your Data, provided that its retention is not required or expressly authorized by the applicable laws, the Data is deleted or anonymized and used for statistical purposes only. Please note that you may always exercise your right to erase your Personal Data stored in our system pursuant to the conditions set out in Section 9 below.


Children who are under the legal age in their country of residence to enter into an agreement with a digital service provider are defined in this Privacy Policy as “Juniors” and are not permitted to register with (SoFriendly), i.e. are not allowed to open an account with our Service.

The age limit that determines whether a person is a Junior is defined by the laws applicable in your country of residence and generally varies from 13 to 16 years of age.

In addition, Juniors should not use or access our Service without the involvement and consent of a parent or guardian. (SoFriendly) Service is intended for the general public. It does not specifically cater to any specific age or interest group. When you visit our Service, we do not know your age. Despite lacking that knowledge, we have designed some Service features protecting young audiences. In particular, a parental control is activated by default when using our Service.

If you are the parent or legal guardian of a Junior, and that child has somehow registered with (SoFriendly) without your approval and contrary to our Terms and Conditions, please contact (SoFriendly)’s support team, available 24/7 through the (SoFriendly) Help Center to initiate an account deletion procedure. When submitting your request, please provide us with a sworn statement confirming that you are either a parent exercising full parental rights or a legal guardian of the child and indicate your full name and address, the child's full name and address, your relationship to the child and your email address. (SoFriendly) will use this information only to process your request and verify that you are the child's parent or legal guardian, and for no other purposes.


    • 1. General

Depending on your country of residence, you may be entitled to access, correct and/or delete the Data you have provided to us, by requesting to do so through the setting of your account, or by reaching out to the (SoFriendly) Help Center via the dedicated section. Any such request needs to be accompanied by a copy of your ID in order to allow us to confirm that you are the data subject or otherwise a person authorized to exercise these rights. Depending on the content of your request you may be asked to provide further documents as needed to confirm conformity of your request with legal requirements and identify the Personal Data to which the request pertains.

    • 2. Change of Privacy Settings for Promotional Communications

You may decide not to receive promotional communications from (SoFriendly) by accessing your account and clicking on "Manage Email Notifications." You may also communicate to us your decision not to receive promotional communications by clicking the "unsubscribe" link in a particular promotional message.

Note that you cannot opt out from receiving all communications from (SoFriendly), including administrative messages, service announcements, and messages regarding the terms and conditions of your account because those may contain important information necessary to using the (SoFriendly) Service.

You can choose to receive push notifications from (SoFriendly) on your device. If you do not wish to receive push notifications, you can use your device’s settings to turn them off.

    • 3. Options for Third-Party Online Behavioral or Interest-Based Advertising on Websites (including Mobile Websites) (SoFriendly) offers its users the ability to make choices about the use of their information for ad targeting. To learn more and exercise your ad preferences on (SoFriendly), please refer to our cookie settings section available on the (SoFriendly) Service or access the Manage Cookies section

Some of the third parties that collect or participate in the collection of information from or about you on the (SoFriendly) Service in order to provide more relevant advertising to you participate in the DAA Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized forum where users can declare their choices about the use of their information for online behavioral advertising. To learn more and to make choices about the use of your information for online behavioral advertising on websites, please click here. Please note that if you exclude online behavioral advertising using this method, this choice will only apply to the specific browser or device from which you opt out.

In addition, some of these third parties may be members of the Network Advertising Initiative ("NAI"), a cooperative of online marketing companies that offers a centralized tool for opting out of interest-based advertising delivered by each of its member companies. If you would like to obtain more information about interest-based advertising and the NAI and make choices about their members’ use of information from or about you on websites, please click here. Please note that if you exclude interest-based advertising using this method, this choice will only apply to the specific browser or device from which you opt out.

    • 4. Options for Third-Party Online Behavioral or Interest-Based Advertising within Mobile Applications

You can define your preferences regarding the use of your information or ad targeting within mobile apps by accessing a cookie preference module available directly within the settings of (SoFriendly)’s mobile applications.

Some of the third parties that collect or participate in the collection of information from or about you on the (SoFriendly) Service in order to provide more relevant advertising to you within mobile applications participate in the DAA Self-Regulatory Program for Online Behavioral Advertising. This program offers a mobile application called the "AppChoices," which provides a centralized location where users can make choices about the use of their information for online behavioral advertising within the mobile application environment. The AppChoices application can be downloaded from your mobile device at or from your device’s app store. Please note that if you exclude online behavioral advertising using this method, this choice will only apply to the mobile device you used to do so.

You may also exercise your choices by accessing your device settings and selecting "Limit Ad Tracking" (for iOS devices) or "Opt out of Interest-Based Ads" (for Android devices), which will allow you to limit our use of information collected from or about your mobile device (such as precise location data) for the purposes of serving online behavioral advertising to you.

    • 5. Additional Information for Residents in the EEA

Individuals located in the European Economic Area, have certain statutory rights in relation to their Data. Subject to statutory exemptions, you have the right to request access to your Personal Data, as well as update, deletion, correction or transfer of this information. You can do this by using the settings and tools provided in your (SoFriendly) account. If you encounter troubles using the settings and tools, or if you do not have a (SoFriendly) account, reach out to the (SoFriendly) Help Center via the dedicated section or send a letter to the attention of our Data Protection Officer at the following address: 140 Boulevard Malesherbes - 75017 Paris, France. Please include within your request a copy of your ID and information about your country of residence, along with any information allowing us to identify your account on the (SoFriendly) Service.

Depending on the content of your request you may be asked to provide further documents as needed to confirm conformity of your request with legal requirements and to identify the Personal Data to which the request pertains.

Furthermore, you are entitled to define and communicate to us rules applicable to your Data upon your death.

Note that, in compliance with applicable laws, some of your Data may not be communicated, rectified or deleted despite your request to do so.

Furthermore, (SoFriendly) Inc., in conformity with the Privacy Shield principles, undertakes to process any complaints related to its processing of Personal Data of Swiss or EEA residents. If you wish to file such a complaint, please reach out to the (SoFriendly) Help Center via the dedicated “Your Personal Data” section or send a letter to the attention of our Data Protection Officer at the following address: (SoFriendly) . P/O TelecomPay Communication Limited, 54 Udo-Edouk Street, Off Abak Road, Akwa Ibom State, Nigeria. Please include within your request a copy of your ID, information about your country of residence, and any information allowing us to identify your account on the (SoFriendly) Service. TelecomPay Communication Limited. will reply to you within 30 days.

If you are not satisfied with the final (SoFriendly). decision regarding your complaint, you may use the other appeal venues defined in the Privacy Shield. In particular, upon exhaustion of the appeal rights with (SoFriendly) . you may file your complaint with the entity declared by (SoFriendly) with the Privacy Shield as competent for dispute resolution purposes, and if not satisfied with that entity’s decision, use the arbitration procedure provided for under the Privacy Shield. For further information on applicable procedures please visit the Privacy Shield web site .

Please note that at the date of publication of the current update of this Privacy Policy, (SoFriendly) Inc. is registered with Privacy Shield and has designated the EU Data Protection Authorities or the Swiss FDPIC, as applicable, as the entities competent for dispute resolution purposes under the Privacy Shield proceedings.

    • 6. Additional Choices for California Residents

        • 6.1. Personal Data Processing Information under the California Consumer Protection Act (“CCPA”)

            • 6.1.a. General

If you are a California resident, in addition to any other information you may find in this Privacy Policy, this section is intended to provide you with specific information required under the California Consumer Protection Act (“CCPA”). In particular, this section describes (SoFriendly)’s practices regarding the collection, use, disclosure and sale of consumers’ Personal Information (hereafter referred to as “PI”) and includes an explanation of your rights regarding your own PI.

Note that rights and obligations provided under the CCPA take effect on 1st January 2020. If you decide to exercise any of such rights your request will be considered as of that date.

The terms “Personal Information,” “Business,” “Third Party” and “Service Provider” used in this section have the same meanings as defined in the CCPA.

If you have an account with (SoFriendly), we identify you by the email address you use to log-in. However, if you do not have an account, in most cases, we rely on a unique online identifier to identify and recognize you.

When you access our Service, a (SoFriendly) cookie (i.e. a small text file) is dropped on your device’s browser. This cookie creates a unique online ID specific to the (SoFriendly) Service and allows us to recognize you when you visit us again (“Service ID”). If you use different devices or different Internet browsers to access our Service (and unless you do so as a logged-in user, in which case we might be able to recognize you regardless of the device or browser used), you are assigned a different Service ID for each of your device/ browser combinations. In other words, if you first accessed the (SoFriendly) Service using Internet Explorer on your laptop, but then visited it on your phone using Chrome you will appear to us as two distinct users. Unless you access the (SoFriendly) Service as a logged-in user, any information that we might have about you is attached to that Service ID.

Due to legal rules applicable to our activities, the lifespan of our cookies is limited to 13 months. Once the 13-month period comes to an end, the (SoFriendly) cookie storing your Service ID expires. If you continue to use our Service, a new (SoFriendly) cookie will be dropped on your browser and a new Service ID will be assigned to you.

As already mentioned in this Privacy Policy, we do not cross-reference Service IDs that are assigned to you on our Service. Unless you are a logged-in user (in which case we may recognize you regardless of the number of Service IDs created for you, and we process your requests in relation to all Personal Data linked to your account), each new Service ID represents to us a new user. For that reason, if you decide to exercise any of your CCPA rights, your decision will only be applied to the Service ID we recognize you under. In particular, if you use the (SoFriendly) Service on several devices or Internet browsers, your decision to Opt-Out of the sale of your PI needs to be expressed on each such device or browser.

8.6.1.b. Collected Personal Information: Categories, Sources and the Business or Commercial Purposes It is Used for.

We may obtain your PI either from you (directly or indirectly) or from our Service Providers or our affiliates. We receive your PI directly from you when you create an account or otherwise communicate with us or interact with our Service. We collect or generate information about you when you use our Service. Your PI may be shared with and by our affiliates if you use their services.

Note that in order to enable the delivery of ads, certain PI may be disclosed to us by advertising p