Privacy Policy of SFriends

This Privacy Policy (“ Privacy Policy ”) describes how Vintry PLC and its related companies (“ Owner ”, “we”, “us”, “our”) collect, use and share personal information of consumer users of th e SFriends website, (the “Website”) , and mobile application ( with the Website, collectively, “SFriends”) .


Vintry PLC
Owner address: Minshull House, 67 Wellington Road North, Stockport, Cheshire, SK4 2LP
Owner contact email:

Types of Data collected

We may collect Personal Data as follows:

Identity Data includes first name, last name, username or similar identifier,photo,date of birth, country of residence and gender.
Contact Data includes email addressand Snapchat, Kik, and Instagram usernames.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Financial Data includes bank account and payment card details.
Usage Data includes information automatically collected through SFriends (or third - party services employed in SFriends), about how you use SFriends , products and services. This can include the following information: Cookies, the IP addresses or domain names of the computers utilized by the Users who use SFriends, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server , the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within SFriends ) and the details about the path followed within SFriends with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User 's IT environment.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Personal Data is freely provided by the User, or, in case of Usage Data, collected automatically when using SFriends.
Unless specified otherwise, all Personal Data requested by SFriends is required , and your failure to provide such Personal Data may make it impossible for SFriends to provide its services. In cases where SFriends expressly states that Personal Data is optional , Users may choose not to share such Personal Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies or other tracking tools by SFriends or by the owners of third - party services used by SFriends serves the purpose of providing the Service requested by the User, in addition to any other purposes described in th is Privacy Policy and in the Cookie Policy, if available. Users are responsible for any third - party Personal Data obtained, published or shared through SFriends and confirm that they have the third party's consent to provide the Personal Data to the Owner.

Mode and place of processing Personal Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases,the Personal Data may be accessible to certain types of persons in charge, involved with the operation of SFriends (administration, sales, marketing, legal, system administration) or external parties(such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place of Processing

The Personal Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User’s Personal Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users should review the section of this Privacy Policy containing details about the processing of Personal Data.

The purposes of processing

Personal Data is collected to allow the Owner to provide SFriends and related services, as well as for the following purposes detailed below: Advertising, Contacting the User, Handling Payments, Hosting and backend infrastructure, Location - based interactions, Managing contacts and sending messages, Registration and authentication, and Social features.

Cookie Policy

SFriends uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action
The User's Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of SFriends or the related services. The User acknowledges and agrees that the Owner may be required to reveal Personal Data in response to requests by public authorities.
Additional information about User's Personal Data
In addition to the information contained in this Privacy Policy, SFriends may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, SFriends and any third - party services may collect files that record interaction with SFriends (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this Privacy Policy.
How “Do Not Track” requests are handled
SFriends does not support “Do Not Track” requests.
To determine whether any of the third - party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Information choices and changes
Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. You may send requests about Personal Data to our contact information above. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Data. You can typically remove and reject Cookies from SFriends with your browser settings. Many browsers are set to accept Cookies until you change your settings. If you remove or reject our Cookies, it could affect how SFriends works for you.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of SFriends that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.
Changes to this Privacy Policy
The Owner reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and possibly within SFriends and/or - as far as technically and legally feasible - sending a notice to Users via any Contact Data available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

For Individuals in the European Union (“EU”) – General Data Protection Regulation (“GDPR”)

This Privacy Policy describes how the Owner collects, uses and shares your personal information. If you are in the EU, you are subject to the GDPR, and the following terms also apply to you. The Owner is the Data Controller and responsible for your Personal Data.

Purposes and Lawful Bases to Process Your Personal Data

This Privacy Policy describes the Personal Data we collect from you and the lawful bases for its collection. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

You have the right to withdraw consent to marketing at any time by contacting us. Specifically, we have a purpose and lawful basis for processing each type of Personal Data as described in this Privacy Policy, which are as follows:

  1. The purpose for collecting your Identity and Contact Data is to register you as a new user, and the lawful basis is the performance of a contract with you.
  2. The purpose for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data is to process and deliver your purchases, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
  3. The purpose for collecting your Identity, Contact, Profile, and Marketing and Communications Data is to manage a relationship with you, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
  4. The purpose for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data is to enable you to partake in a contest, competition or complete a survey, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business).
  5. The purpose for collecting your Identity, Contact, and Technical Data is to administer and protect our business and SFriends, and the lawful basis is that it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
  6. The purpose for collecting your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data is to deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, and the lawful basis is that it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
  7. The purpose for collecting Technical and Usage Data is to use data analytics to improve SFriends, marketing, customer relationships and experiences, and the lawful basis is that it is necessary for our legitimate interests (to define types of customers for our products and services, to keep our service updated and relevant, to develop our business and to inform our marketing strategy).
  8. The purpose for collecting Identity, Contact, Profile, Usage, and Technical Data is to make suggestions and recommendations to you about goods or services that may be of interest to you, and the lawful basis is that it is necessary for legitimate interests (to develop our products/services and grow our business).

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out forth in this Privacy Policy.

We may have to share your Personal Data with the parties and for the purposes described in this Privacy Policy. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we 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 process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


Under certain circumstances, EU residents have rights under data protection laws in relation to their Personal Data. If you are an EU resident, you have the right to:

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Definitions and legal references

Personal Data
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
The individual using SFriends who, unless otherwise specified, coincides with the Personal Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor) The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this Privacy Policy.
Data Controller (or Owner) The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of SFriends. The Personal Data Controller, unless otherwise specified, is the Owner of SFriends.
SFriends The means by which the Personal Data of the User is collected and processed.
Service The service provided by SFriends as described in the relative terms (if available) and on this site/application.
European Union (or EU) Unless otherwise specified, all references made within this Privacy Policy to the European Union include all current member states to the European Union and the European Economic Area.
Cookies Small piece of data stored in the User's device.

Legal information This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This Privacy Policy relates solely to SFriends, if not stated otherwise within this Privacy Policy.

Last updated: August 22 2019