When we say “Soda”, we mean “Soda SEA Pte. Ltd. ”; the company that is developing Soda as a platform to connect like-minded people in a curated way.
Our mission is to bring like-minded people together in real life. We don’t trade, swap, or make money from personal data in any other way.
Data protection laws give you rights, and we want to make sure we’re doing it correctly. If you have any questions, concerns, or requests about your data, please do get in touch with us at email@example.com.
The sections below describe how your personal data is processed according to the relationship between you and Soda. If you think there is any missing information, or if the information presented is unclear or incorrect, please let us know so we can fix it.
3. Where do we get your data from?
We either get the information about you directly from you, or from your browser (e.g. through cookies) and the way you use our platform, or from sources that you share with us (e.g. LinkedIn).
4. Why do we process your data and on what legal grounds?
We will not collect and/or use your personal data without your knowledge or without reason. The sections below tell you about the details of why we process your personal data and on what legal grounds.
When you register on our landing page to get early access
Verification of your professional identity To keep the community safe for everyone, we use LinkedIn profiles to verify your professional identity and serve as a second-layer verification at the time of joining. We do that based on our legitimate interest to keep our community safe. This verification is done by a human and is not automated. You can object to any processing of your personal data where that processing is based on legitimate interests. If you make an objection, we will revisit the processing and assess the interests and the risks and decide on a case-by-case basis whether we should cease the processing of your personal data. If we consider that we have compelling interests that outweigh your preferences then we will explain our reasoning to you.
When you use our platform
To make your login to our platform possible, we collect your email address, which we process on the legal basis of contractual obligation as long as you are registered. We will also ask you for your phone number for a 2-factor authentication. We need it because having two distinct forms of identification strengthens the security of your account and your personal data with it.
Matching algorithm for customized and personalized huddle suggestions
The core of our service is the platform that suggests connections to people according to their interests, professional and educational background, and other social and professional characteristics. In order for it to work, we analyse the following personal data:
your LinkedIn information, such as your professional identity and educational background. We will only retrieve data about you from LinkedIn if you have given us your consent. You can also withdraw your consent any time.
interests that you choose during onboarding and as you may update in your profile information from time to time. We need this information about you to provide the service to you. You can however change this information anytime by going to your profile in the app.
your behaviour on the platform, the feedback that you give and receive as well as connections and affiliations with other people. This is also needed for our algorithm to be able to provide you with best suggestions of gatherings and for optimisation of group dynamics.
Chats Our platform also allows you to communicate with other people who are part of the event (huddle). The chat option is available 48h before and after the event. In rare instances and on a needs-only basis, we may access the communication data from the chats for the purpose of resolving conflicts or preventing fraud.
Marketing Analytics and cookies We use Matomo, a web analytics service, to collect data about your interaction with our website. This service is an open source project developed by the Matomo team members as well as many other contributors around the globe. Matthieu Aubry is the legal representative of the Matomo project. You can read more on Matomo’s privacy here and if you still have any questions about their privacy practices, you can contact their privacy team at firstname.lastname@example.org.
The purpose of collecting your data in this way is for us to analyse the way users interact with our platform and to improve your experience when using our site accordingly. The types of data we collect with this tool include: usage data (the website from which you visited us from, the parts of our site you visit, the date and duration of your visit, your anonymised IP address, information from the device you used during your visit – its type, operating system, screen resolution, language, country you are located in, and web browser type.)
We use Amplitude for analytics and customer support purposes as described herein above. As for analytics purposes, Amplitude provides us with different analytics tools that enable us to research and analyze Your use of the Service. As for customer support purposes, Amplitude helps us to respond to Your requests for technical support. For example, it enables us to track Your interaction with our App and in order to detect particular technical issues with our App. For more information on the privacy practices of Amplitude, please visit https://amplitude.com/privacy
5. Your rights under the Personal Data Protection Act (PDPA) and GDPR:
To be informed about the processing
To have access to your data and details of our processing
Exercising this right is known as “making a subject access request”:
You have the right to ask us:
whether we are processing your personal data,
why we are doing so,
under what lawful basis we are processing your data,
the categories of personal data about you which we are processing,
whether the data is being sent outside the Singapore,
the names of any other Data Controllers your data has been passed to, and the purpose and lawful basis for the transfer,
how long we’re going to keep the data, or what criteria we’ll use to decide whether to keep it,
for a copy of the data we are processing.
We’d much appreciate it if you would use our email email@example.com to make a subject access request, as this allows us to identify and handle requests consistently, however you don’t have to use the form – you can use any preferred way of contacting us to make the request. We’ll need to ask you for some information to make sure the request is valid though, so it would save time to use our form from the start.
To object to some processing
Objecting to direct marketing You have the right to ask us to stop processing your personal data for direct marketing purposes, and if you make this request we will stop sending you marketing and exclude your data from any analytics or reporting we do for marketing. We’d rather keep your contact details on our suppression lists so that if we do collect your data again in the future, we can be sure to exclude you from receiving our marketing materials however if tell us that you prefer us to stop all marketing-related processing of your personal data, then we will remove your details from these lists.
Objecting to processing based on legitimate interests
You can object to any processing of your personal data where that processing is based on legitimate interests. When you make an objection, we will revisit the processing and assess the interests and the risks and decide on a case-by-case basis whether we should cease the processing of your personal data.
This right is sometimes referred to as “the right to be forgotten”. It only applies in narrow circumstances, where:
you have withdrawn your consent and there is no further legitimate interest in continuing to process the data,
your objection to our processing under legitimate interests outweighs those interests,
the processing of your personal data is no longer necessary,
there is a law that requires the data to be deleted, or
the processing is unlawful (we work hard to make sure this is never the case!)
We can’t erase any data which we are required by law to process, but we will highlight and explain this to you if your request includes this data.
If we consider that we have compelling interests that outweigh your preferences (which might be to keep our IT systems secure, or maintain auditing and accounting records) then we will explain our reasoning to you.
To have some data deleted
you have the right to have your data erased from our systems and files.
To limit how your personal data is used Under some circumstances, you can limit how your personal data is used by us If :
the personal data we are processing is inaccurate,
our processing is unlawful,
the data is no longer necessary for the original purpose of processing but needs to be kept for potential legal claims, or
you have objected to processing carried out under legitimate interests and we’re still in the process of determining whether there is an overriding need to continue processing.
you have the right to restrict the processing. This means that the data will only be processed:
with your consent,
for the establishment, exercise or defence of legal claims, to protect someone else’s rights, or
if there is an important public interest justification for processing.
To take your data elsewhere
The right of data portability says that you can ask for any data that we process by automated means (which means ‘using a computer’) which:
you provided to us either on the basis of consent or
because it was necessary for a contract that you are directly a party to;
to be provided back to you in a computer-based format, or sent directly to another Data Controller.
This is mostly intended for you, the individual end user or consumer, to be able to switch providers without your data being held hostage.
To query automated decision-making We neither use automated decision-making nor your personal data to automatically assess aspects of your personality (automated profiling). But if we did, you would have the right to ask us to explain the logic behind any such decisions and for the decision to be reviewed by a human being, if the decision had an effect on your rights or freedoms.
To have data corrected If any of the data we hold on you is inaccurate or out of date, please let us know so that we can correct it as quickly as possible.
If you’re not happy with any aspect of how we process your personal data, please let us know so that we can make things right. If you’re not satisfied with our response, you can make a complaint to the Data Protection Authorities.