Welcome to Surfly (“we,” “our,” or “us”). We operate the Surfly mobile application (the “App”) and associated services (collectively, the “Service”).
Your privacy is critically important to us. This Privacy Policy explains what information we collect, how we use and share it, and the choices you have regarding your data when you use our global social networking platform. By accessing or using Surfly, you agree to the practices described in this policy.
To connect you with friends and communities globally, we collect information you provide directly, data generated automatically, and information from third parties.
Account Registration: When you create an account, we collect your name, username, email address, password, date of birth, and gender (where applicable).
Profile Information: You may choose to customize your profile by adding a profile picture, bio, relationship preferences, or other personal details.
User Content: We process and transmit the content you create, including instant messages, photos, videos, and comments.
Customer Support & Communications: If you contact us directly, we receive the contents of your message, attachments, and any other information you choose to provide.
Device and Log Information: We collect data about the device you use to access the App, including IP address, hardware model, operating system version, unique device identifiers (e.g., IDFA/GAID), mobile network information, and App crash logs.
Usage Data: We track your activity on the App, such as features used, time spent, login frequencies, and your interactions with other users or in-app games.
Cookies and Tracking Technologies: We utilize mobile SDKs and similar technologies to remember your preferences and analyze App performance.
Third-Party Sign-In: If you link, connect, or log in to Surfly using a third-party service (e.g., Apple, Google, or Facebook), they send us info such as your profile data and email address as permitted by that service’s settings.
We process your data based on contract fulfillment, legitimate business interests, legal compliance, or your explicit consent. Primary purposes include:
To Provide and Improve the Service: Managing your profile, facilitating real-time messaging, photo/video sharing, and hosting in-app games.
To Enhance Personalization: Suggesting friends, connections, or content tailored to your preferences.
To Maintain Safety and Security: Monitoring for spam, abusive behavior, or violations of our Terms of Service to protect our community.
To Communicate With You: Sending operational notices, security alerts, technical updates, and responding to support queries.
Analytics: Conducting research and analyzing user trends to improve the App’s performance and user experience.
We do not sell your personal data. We only share your data under the following circumstances:
With Other Users: Your public profile information, user content (posts, photos, videos), and online status may be visible to other Surfly users depending on your privacy settings.
With Service Providers: We share data with trusted third-party vendors who perform services on our behalf (e.g., cloud hosting, data analytics, customer support software, and payment processing). These providers are contractually bound to protect your data.
For Legal and Regulatory Reasons: We may disclose your information if required to do so by law, subpoena, court order, or governmental request, or to protect the rights, property, and safety of Surfly, our users, or the public.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, or sale of assets, user information may be transferred as part of the transaction.
We retain your personal data only for as long as your account is active or as needed to provide you with the Service.
Account Data: Retained for the lifespan of your account.
User Content: Messages, photos, and videos are retained until deleted by you or until your account is terminated. Residual backup copies may persist briefly in our systems before complete purging.
Legal Hold: We may retain certain data for longer periods if required by statutory obligations or to resolve disputes.
Depending on your jurisdiction (such as the EU/UK under GDPR, or California under the CCPA/CPRA), you possess the following rights regarding your personal information:
Access and Portability: The right to request copies of your personal data in a structured, machine-readable format.
Correction/Rectification: The right to update or correct inaccurate or incomplete profile data directly via the App settings.
Erasure ("Right to be Forgotten"): The right to request the deletion of your account and associated personal data.
Object or Restrict Processing: The right to object to our processing of your data under certain conditions.
Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time through your device settings (e.g., camera or notification permissions).
To exercise these rights, please contact us at the email provided in Section 9.
Surfly operates globally, meaning your information may be transferred to, stored, and processed in countries outside of your home country (including the United States and other regions). These countries may have data protection laws that differ from those of your jurisdiction. We utilize standard contractual clauses and recognized legal mechanisms to ensure your data receives an equivalent level of protection wherever it is processed.
Surfly is strictly intended for individuals aged 18 and older (or the legal age of majority in your jurisdiction). We do not knowingly collect or solicit personal data from anyone under the age of 18. If we learn that we have inadvertently collected personal data from a minor, we will delete that information as swiftly as possible. If you believe a minor has created an account, please contact us immediately.
We may update our Privacy Policy from time to time. When changes are made, we will update the "Last Updated" date at the top of this policy and notify you via an in-app alert or email if the modifications significantly alter your rights. Your continued use of the App after an update constitutes acceptance of the revised policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection Officer (DPO) at:
Email: 838894989@qq.com
Legal Disclaimer: This draft is provided for informational and structural planning purposes. Before publishing your privacy policy to the Apple App Store, Google Play, or your official website, it should be reviewed by your legal counsel to ensure precise alignment with your specific technical infrastructure, backend data flow, and any regional laws unique to your business entity.