Effective Date: December 1, 2024
Welcome to the Privacy Policy of Sup Connection, LLC. (“Sup,” “we,” “us,” or “our”). Sup provides a digital platform that helps people explore the outdoors activities with a collection of detailed activity description provided by users, activity reviews, and photos crowdsourced from our community. This Privacy Policy applies to the following services operated by Sup (collectively, the “Service”): • www.whatsupstrangers.com and other websites owned and/or operated by Sup that contain a link to this Privacy Policy (collectively, the “Site"); • All mobile applications that contain a link to this Privacy Policy (the “Sup Apps”); and • All services made available by Sup through the Site and the Sup Apps, collectively, the “Service”. This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. This Privacy Policy constitutes an integral part of our Terms of Service, accessible at: https://www.whatsupstrangers.com/term. Please read this Privacy Policy before using our Service or submitting any Personal Data to Sup and contact us if you have any questions.
Information We Collect
When you contact us or interact with our Service, we collect information that alone or in combination with other information could be used to identify you (“Personal Data”) as follows: • Personal Data You Provide to Us: We collect Personal Data when you sign up for our Service through the Site or a Sup App. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it may include any of the following: o Account Data: When you sign up, some information is required to create an account on our Service, such as your name, username, email address, phone number and mailing address. o Payment Data: If you choose to purchase a subscription to our Service via credit card, debit card or other payment method, our third party payments processor (Stripe, Inc. or “Stripe”) will process certain payment and billing information, such as billing address, payment card details, and authentication features. That information is collected by Stripe directly, and we do not collect or store it. If you have questions about how Stripe protects such information, please read Stripe’s services agreement and privacy policy. o Social Media Data: We have pages (“Social Media Pages”) on social media sites like Facebook, Instagram, Pinterest, Twitter, and LinkedIn (each a “Social Media Site”). The platforms that host our Social Media Pages or Social Media Features may provide us with aggregate information and analytics regarding the use of our Social Media Pages and Social Media Features. o User Generated Content: User-generated content, such as profile pictures, photos, images, videos, posts, comments, questions, messages, user interactions, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data. o Contacts Book Data: Our mobile applications may allow you to synchronize the numbers in your Contacts address book on a regular basis in order to identify any friends and/or relatives who use the Service. When you do so, we will ensure that the relevant data is encrypted and will not use it for any purpose other than matching your contacts to users of the Service. If any of your contacts are using the Service, we will let you know so that you can connect with them. You can revoke our access to your Contacts address book at any time through your mobile device settings. o Additional Information: To help improve your experience or enable certain features of the Service, you may choose to provide us with additional information, such as your date of birth/age, gender, profile picture, city of residence, community username, statistics on your activity history and your reviews and photographs of activities. • Information We Generate From Your Use of Our Service: When you visit, use, interact and register with the Service, we may automatically generate certain information about your visit, use, interactions or registration. For example, we may monitor the number of people that visit our Site or Sup Apps, peak hours of visits, which page(s) are visited on our Site or Sup Apps, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site- and Sup App-navigation pattern. In particular, the following information is created and automatically logged in our systems: o Log Data: Information that your browser automatically sends whenever you visit the Site or Sup Apps. Log data includes your IP address (so we understand which country you are connecting from when you visit the Site or Sup Apps), browser type and settings, the date and time of your request, and how you interacted with the Site or Sup Apps. o Cookies Data: We use cookies and similar technologies to operate and administer our Site and Sup Apps, make it easier for you to use the Site and Sup Apps during future visits, and gather usage data on our Site and Sup Apps. For more information about the technologies used and information collected on our Site and Sup Apps, please refer to our Cookie Policy, which forms part of this Privacy Policy. o Device Data: Includes the model of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings. We may also collect data from your device to estimate a variety of metrics like the time, frequency and duration of, and calories burned during, your activities for the purpose of calculating your Usage and Activity Data (described below). o Usage and Activity Data: We collect information about how you use our Site and Sup Apps, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of, and calories burned during, your activities. o Geolocation Data: If you have enabled location services for an Sup App on your mobile device or on your computer via the Site, we may collect your precise location information based on city, state, zip code, country, latitude and longitude. Sup may also derive your approximate location from the IP address of your computer or mobile device. Geolocation data is used for purposes of directing you to nearby trails and parks and offering other relevant content and services. • Information We Receive From Third Parties. If you elect to authenticate to our Service using your account on another service (such as a Facebook, Google, or Apple account), we may receive from the other service information like your external account name as well as other information you may choose to make available to us based on your external account settings, such as contact lists and profile photos (if any). You can stop sharing the information from the other service with us by removing our access to that other service.
How We Use Personal Data
We use your Personal Data for a variety of purposes, which are listed in the table below. If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy to explain any such new purpose. In addition, in respect of each of the purposes for which we use your Personal Data, privacy laws in certain jurisdictions require us to ensure that we have a legal basis for that use. Most commonly, we will rely on one of the following legal bases: • Where we need to process your Personal Data to deliver our Service to you, or to otherwise perform our contractual obligations to you (“Contractual Necessity”). • Where we need to process your Personal Data for our legitimate business interests, and your interests and fundamental rights do not override those interests (“Legitimate Interests”). • Where we need to process your Personal Data to comply with a legal or regulatory obligation (“Compliance with Law”). • Where we have your specific consent to carry out the processing for the purpose in question (“Consent”). We have set out below, in a table format, the various purposes and legal bases we rely on in respect of the processing of your Personal Data: Purpose Legal Basis Account creation - to create and manage your account on the Service. Contractual Necessity Service delivery - to operate and deliver our Service to you. Contractual Necessity Live Share Group - to communicate with your Live Share Notification Group regarding your whereabouts as described on our Service. Contractual Necessity Payments processing - to process your payments via our third-party payments processor. Contractual Necessity Customer support - to deliver customer support to you and respond to your queries. Contractual Necessity Contacts syncing – to match the phone numbers in your Contacts address book to users of the Service, if you have chosen to do so. Contractual Necessity Service improvement – to analyze how you use our Service and to improve it. Contractual Necessity Fraud prevention – to keep our Service and associated systems operational and secure. Contractual Necessity Legal compliance – to comply with our legal obligations, for example our accounting and tax reporting obligations. Compliance with Law Marketing – to send you information about our products and services (including via email). Consent Marketing. We may contact you to provide information we believe will be of interest to you. For instance, if you elect to provide your email address, we may use that information to send you promotional information about our products and services. If we do, we will only send you such emails if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving emails at any time by following the instructions contained in each promotional email we send you or by contacting us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site and Services and to respond to your requests.
How We Share and Disclose Personal Data
In certain circumstances, we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below: • Affiliates: Other companies in our corporate group may help us deliver our Service to you. • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with service providers, including hosting, cloud services and other information technology services providers; email communication software providers and email newsletter providers; data base and sales services; customer relationship management, customer engagement, and customer feedback services; payment processors; security services; and analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets. • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with legal or regulatory obligations, including to respond to lawful requests from public authorities and to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site, or the public, or (v) protect against legal liability. • Other Users. Your profile and other User Generated Content (except for private messages) may be visible to other users of the Service (which may include all users of the Service or a limited number of users, depending on your privacy settings). For example, other users of the Service may have access to your information if you chose to make your profile or other personal information available to them through the Service, and may also have access to content that you submit to the Service such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of information.
Data Retention
We keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer. If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies. To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Update Your Information
If you need to change or correct your Personal Data, please contact us at support@whatsupstrangers.com. We will address your request as required by applicable law.
Children's Privacy
Our Service is not directed to children who are under the age of 13. Sup does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 13 has provided Personal Data to Sup through the Service, please contact us and we will endeavor to delete that information from our databases.
California Privacy Rights Disclosures
Collection, Disclosure, and Use of Personal Data: The categories of Personal Data we have collected in the preceding 12 months are described above in the “Information We Collect” section. In the preceding 12 months, we have disclosed for business purposes each of the categories identified in that section to the categories of third parties identified in the “How We Share and Disclose Personal Data” section. The business and commercial purposes for collecting Personal Data are described in the “How We Use Personal Data” section. We collect Personal Data directly from you and from external accounts you use to log-in to the Service.
Privacy Rights
Where provided for by law and subject to any applicable exceptions, California residents may have the following rights under the California Consumer Privacy Act of 2018 (“CCPA“): • To know the categories of Personal Data that Sup has collected about you, the business purpose for collecting your Personal Data, and the categories of sources from which the Personal Data was collected. • To access the specific pieces of Personal Data that Sup has collected about you. • To know whether Sup has disclosed your Personal Data for business purposes, the categories of Personal Data so disclosed, and the categories of third parties to whom we have disclosed your Personal Data • To have Sup, under certain circumstances, delete your Personal Data; and • To be free from discrimination related to the exercise of these CCPA rights.
Sup does not sell your Personal Data
If you would like to exercise any or all of these rights, you may do so by clicking “Make a Privacy Request” or contacting support@whatsupstrangers.com. Your authorized agent may submit requests in the same manner. Once we receive your request, we will verify your identity by sending an email to the email address you provide to us. If you have questions about your rights or our disclosures under the CCPA, or to request access to an alternative format of this notice, you may reach us at support@whatsupstrangers.com.
Online Tracking and Do Not Track Signals
We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will describe how we do so in this Privacy Policy.In addition to the privacy rights set forth above, residents of Oregon may request a list of specific third parties, other than natural persons, with whom Sup may share any customer data by emailing support@whatsupstrangers.com.
International Transfers
Sup is based in the United States. Some of our vendors and service providers may also be located in the United States or another country. As such, any processing of your Personal Data may involve an export of your Personal Data outside of your country of residence, including to countries which may have data protection laws that are less stringent than the laws in effect in the country in which you are located. Whenever we transfer your Personal Data out of your country of residence, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards which comply with applicable privacy laws. If you would like to receive more information about these safeguards, please contact us.
Links to Other Websites
The Site and Sup Apps may contain advertisements for or links to other websites, products, or services not operated or controlled by Sup Connection, LLC including Social Media Sites (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.