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Legal - Privacy Policy

SUPERTECH PRIVACY POLICY

Last updated: Oct 15, 2024

This Privacy Policy explains how Supertech, Inc. (“Supertech”) is committed to protecting your privacy and ensuring that you feel comfortable using the Supertech websites (https://supertech.ai), services, mobile applications, and our platform (collectively our “Services”). This Privacy Policy is applicable worldwide.

This policy describes our data handling practices and how we collect and use the Personal Information and other information you provide during your interactions with us and our Service. “Personal Information” means any information that can be used to individually identify a person, and may include, but is not limited to name, email address, postal or other physical address, credit or debit card number, title, and other personally identifiable information including metadata, and user content. Personal Information does not include information that cannot be used to identify you, which may include internet protocol (“IP”) address, browser type, internet service provider, operating system, or device type, and information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person or household (collectively “De-Identified Data”).

This Privacy Policy is a binding contract and by using our Service you agree to it. This Privacy Policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website.

COLLECTION OF PERSONAL INFORMATION

In order for you to register with our Services, you must provide us with your name and email at a minimum. You may also have chosen to provide other Personal Information, including but not limited to information required to process online payments.

Overall, we collect the following categories of Personal Information about you when you use or otherwise interact with our Services:

  • Username
  • Email address
  • Home/work/mobile telephone number
  • Postal or other physical address
  • IP addresses
  • Operating system
  • Language preferences
  • Location Information
  • Referring URLs
  • Device Name
  • Device description
  • Device identifiers

We do not collect or process any sensitive Personal Information.

Collection of Application Data. If you use our mobile application(s), we may also collect the following information if you choose to provide us with access or permission:

  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, contacts, storage, biometry, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our mobile application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the mobile application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our mobile application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All Personal Information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Automatic Collection

Supertech and our third-party service providers automatically collect some information about you when you use our Services, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes IP address, Internet service provider, log and usage data, device data, location data, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, sections of the Services visited, number of links you click while on the Services, search terms, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, website traffic and related statistics, keywords and/or other data.

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Collection With Cookies and Tracking Technologies

When you use the Services, we may also collect certain information by automated or electronic means, using technologies such as cookies, browser analysis tools, and web server logs, in each case consistent with this Privacy Policy and our Cookie Policy. As you use the Services, your browser and devices communicate with servers managed by our business partners, our service providers or us to record the interactivity and to fulfill your requests for services and information.

In many cases the information we collect using cookies and other tools is used in non-identifiable ways and without any reference to Personal Information. For example, we use information we collect about users to optimize the Services and understand its traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy and our Cookie Policy govern how we use that information.

Collection with Social Logins

Our Services may offer the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we may receive certain profile information, including Personal Information, about you from your social media provider. The Personal Information in such shared profile information may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the Personal Information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your Personal Information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your Personal Information, and how you can set your privacy preferences on their sites and apps**.**

PROCESSING OF YOUR PERSONAL INFORMATION

We will use your Personal Information only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Information in this manner, you can request that your account be deactivated by contacting us at [email protected].

We will only process your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Services) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:

  • Administering, personalizing, improving or operating our Services and business;
  • Better understanding your needs and interests;
  • Fulfilling requests you make related to the Services;
  • Complying with our legal obligations, resolving disputes with users, enforcing our agreements;
  • Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity, and;
  • Responding to inquiries from you or our third-party service providers.

We collect and/or process your Personal Information in connection with the following activities related to our Services:

  • Account registration;
  • Delivering and facilitating delivery of the Services to you;
  • Use and testing of certain Services features, features in development;
  • Generating reports based on information collected from use of our Services;
  • Requesting service and support for our Services and providing such support;
  • Placing transactions or orders;
  • Conducting surveys and processing information;
  • Conducting research relating to our Services;
  • Billing and collecting payments for our Services;
  • Customizing and personalizing the content and features you see;
  • To keep you up to date on the latest Service announcements, updates, upgrades, system enhancements, special offers, and other information;
  • To conduct audits and provide support for our Services;
  • To meet contract our legal obligations, and;
  • Communicating with you by email, telephone or regular mail regarding news updates, special promotional offers, our products and services, or other information which may be of interest to you. If you later wish to opt out of receiving such promotional communications from us at any time, simply follow the “Opt-Out” instructions.

If you no longer wish to receive certain communications from us, you may opt-out of receiving them by following the unsubscribe instructions included in each communication or by emailing us at [email protected]. However, you will not be able to opt-out of all communications, such as those legally required notices or required Service notices.

SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTY SERVICE PROVIDERS

Supertech does not sell or rent your Personal Information to any third party for any purpose - including for advertising or marketing purposes. Furthermore, we do not share Personal Information with any third parties except in the limited circumstances described in this Privacy Policy.

We work with vendors, service providers, and other partners to help us provide our Service by performing tasks on our behalf. We may need to share or provide information (including Personal Information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. These service providers do not have the right to use your Personal Information we share with them beyond what is necessary to assist us. These service providers must adhere to confidentiality and security obligations in a way that is consistent with applicable law and their own terms and policies.

The third parties we work with to provide our Service are:

  • Google Analytics for analytics on our websites;
  • Google Cloud Platform, Firebase, Amazon Web Services, Oracle Cloud Infrastructure, for data storage, API hosting, backend processing and managed services;
  • Google Workspace, for email services, Google Sheet, Google Form, and Google Drive;
  • Engagebay, for sales contact forms and services; and
  • Vercel, for hosting of our websites.

If you would like to opt out of third party tracking via Google Analytics and Google Analytics 4, please visit https://tools.google.com/dlpage/gaoptout.

This Privacy Policy only applies to information collected during your use and access of the Service or any other interactions you may have with Supertech. Our Service contains links to other locations on the internet that are not owned or controlled by us. We are not responsible for the privacy practices of other websites or services. We encourage you to read the privacy statements of each website that collects your Personal Information.

We may also share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates would include a parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

We may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of investigating, preventing, or taking action regarding suspected or actual illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, to comply with subpoenas, or as otherwise required by law. In the event that we receive a subpoena affecting your privacy, we will notify you unless prevented by applicable law, court order, rule or regulation, but are not required to quash the subpoena ourselves.

DE-IDENTIFIED DATA

We may use De-Identified Data to test features in development, and analyze the information we have to evaluate and improve products and services, develop new services or features, and conduct audits and troubleshooting activities. De-identified Data will have all direct and indirect personal identifiers removed. This includes, but is not limited to, name, ID numbers, and date of birth. Furthermore, we agree not to attempt to re-identify De-Identified Data and not to transfer De-Identified Data to any party unless that party agrees not to attempt to re-identify any Personal Information from such data. We may share this De-Identified Data with our affiliates, agents, advertisers, manufacturers and business partners. We may also disclose De-Identified Data in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.

CHOICE

We provide you with the opportunity to opt out of having your Personal Information used for certain purposes when we ask for this information; however, this may limit your ability to fully use our Services.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at [email protected].

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, Through the settings in the mobile app, or by contacting us at [email protected]. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

DATA SUBJECT RIGHTS

You have certain rights with respect to your Personal Information as set forth below.

To make any of the following requests, contact us at [email protected].

  • Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.

  • Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.

  • Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.

  • Erasure: You can request that we erase some or all of your Personal Information from our systems.

  • Restriction of Processing: You can ask us to restrict further processing of your Personal Information.

  • Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.

  • Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

  • Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with a supervisory authority.

SECURITY

Supertech uses reasonable administrative, technical, and physical security measures to protect data about Supertech customers. Supertech stores your Personal Information and other data on servers that may be located in Belgium, Finland, and in the United States. If you would like to know more, please email [email protected].

You are responsible for maintaining the strict confidentiality of your account login credentials, and for any activity that occurs under your account credentials. Notify us if you suspect any unauthorized use of your account or other breach of security.

DATA RETENTION

We retain Personal Information only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

  • mandated by law, contract or similar obligations applicable to our business operations;
  • for preserving, resolving, defending or enforcing our legal/contractual rights; or
  • as needed to maintain adequate and accurate business and financial records.

If you have any questions about the security or retention of your Personal Information, please contact us at [email protected].

GOVERNING LAW

This Privacy Policy and the privacy practices of Supertech are governed by the internal laws of the State of Colorado, United States.

IMPORTANT NOTICES TO NON-U.S. RESIDENTS

The Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to the United States. By providing us with any information through the Site, or the Services, you consent to this transfer.

We may transfer your Personal Information to third parties acting on our behalf for the purposes of processing or storage. By using any of our Services or providing any Personal Information for any of the purposes stated above, you consent to the transfer and storage of your Personal Information, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Information on U.S. servers.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your Personal Information. As such, we may rely on the following legal bases to process your Personal Information:

  • **Consent. **We may process your Personal Information if you have given us permission (i.e., consent) to use your Personal Information for a specific purpose. You can withdraw your consent at any time.

  • Performance of a Contract. We may process your Personal Information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

  • Legitimate Interests. We may process your Personal Information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your Personal Information for some of the purposes described in order to:

    • Send users information about special offers and discounts on our products and services;

    • Analyze how our Services are used so we can improve them to engage and retain users;

    • Support our marketing activities;

    • Diagnose problems and/or prevent fraudulent activities; and

    • Understand how our users use our products and Services so we can improve user experience.

  • Legal Obligations. We may process your Personal Information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

  • Vital Interests. We may process your Personal Information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your Personal Information if you have given us specific permission (i.e., express consent) to use your Personal Information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your Personal Information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;

  • For investigations and fraud detection and prevention;

  • For business transactions provided certain conditions are met;

  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;

  • For identifying injured, ill, or deceased persons and communicating with next of kin;

  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;

  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;

  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;

  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;

  • If the collection is solely for journalistic, artistic, or literary purposes; and

  • If the information is publicly available and is specified by the regulations.

DATA PROTECTION ADDENDUM AND EC STANDARD CONTRACTUAL CLAUSES

Supertech is responsible for the processing of Personal Information it receives in accordance with a DPA that incorporates The European Commission’s Standard Contractual Clauses (or “SCCs”), which DPA may be entered upon request. If entered into, we will comply with the DPA for all onward transfers of Personal Information from the EU or Switzerland, including onward transfer liability provisions. The SCCs incorporated into the DPA are standardized contractual terms, recognized and adopted by the European Commission, with the primary purpose of ensuring that any Personal Information leaving the European Economic Area (“EEA”) will be transferred in compliance with EU data-protection law. In certain cases, Supertech will transfer Personal Information in accordance with the European Commission-approved Standard Contractual Clauses, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087

Supertech, complies with the SCCs as set forth by the European Commission regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms in this Privacy Policy and the DPA, including the SCCs, the DPA shall govern.

The European Commission’s SCCs incorporate the principal EU General Data Protection Regulation (GDPR) requirements covering access, disclosure, security and transparency of Personal Information, and sets forth a framework for U.S. companies, and EU entities working with U.S. companies, to meet the requirements of the GDPR. If entered into, both you and Supertech will comply with the DPA, including the SCCs, so that Supertech’s EU-based users can share Personal Information with us and remain compliant with the GDPR.

We are committed to protecting your privacy in compliance with the European Commission’s SCCs. EU and Swiss Individuals with inquiries or complaints regarding our Privacy Policy can contact us [email protected].

We work hard to promptly respond to any requests we receive regarding privacy and data protection. If you do not receive a timely acknowledgement of your request from us, or if we have not addressed your request to your satisfaction, you agree to refer the matter to the International Center for Dispute Resolution / American Arbitration Association (ICDR/AAA). ICDR/AAA is an independent recourse mechanism chosen by Supertech. You may get more information or contact ICDR/AAA at https://www.icdr.org/about_icdr. The services of ICDR/AAA are provided at no cost to you. Under certain conditions, individuals may invoke binding arbitration when the dispute resolution procedures of ICDR/AAA have been exhausted.

CALIFORNIA LAW COMPLIANCE

We permit residents of California to use our service, and fully comply with California’s privacy laws to the extent applicable to Supertech’s Services. California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service 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 send an email to [email protected].

AMENDMENTS

We may modify the terms of this Privacy Policy from time to time. In the event of any material change to our Privacy Policy, in Supertech’s sole discretion, you may be notified by email of such change, if you are registered user of the Service. If any change is unacceptable to you, you should immediately cease use of the Service. Your continued use of the Service following a notice of a change in the Agreement via the Service will constitute your binding acceptance of the changes.

COMMENTS AND QUESTIONS.

If you have any comments or questions, you may send them by email to [email protected].