Effective Date: 15 August, 2022
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Last Updated on: 20 November, 2023

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This privacy policy (“Policy”) explains how SuprStack, Inc. or any of its affiliates or subsidiaries (“We”, “Us”, “Our”) Processes Personal Data collected from natural persons (“You”) as specified in clause 2 below, as a Controller.

Capitalised terms not specifically defined herein shall have the meaning ascribed thereto in the Terms.
1.1 “Controller” means 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.
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1.2 “Customer” means the natural or legal person that has subscribed to SuperSend by agreeing to the Terms.
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1.3 “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
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1.4 Process/Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
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1.5 “SuprSend” means Our proprietary platform for API-led automation process for outreach across email, LinkedIn, Twitter, and other messaging channels, including individually and collectively API, Software, and any Documentation and any updates, modifications, or improvements thereto.
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1.6 “Terms” shall mean the Terms of Service available at https://www.suprsend.com/terms.

2.3 If You provide Us with any Personal Data relating to other individuals, You represent that You have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Policy. If You believe that Your Personal Data has been provided to Us improperly, please contact Us by using the information in clause 11 below.
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2.4 In addition to the details provided in the table above, We may also share Your Personal Data with  an entity to which we divest all or a portion of Our business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of Our business.Law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of Our activities.Professional advisors who advise and assist Us in enforcing Our contracts and policies, handling Our claims, effective management of Our company and in relation to any disputes We may become involved in.

3.1 If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.

3.2 We will normally collect Personal Data from You only where it is needed to perform a contract with You, where the Processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We Process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

3.3 If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause 11.

4.1 We mainly Process Personal Data in the United States and/or India. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.

4.2 If You are a resident of the European Economic Area and when Your Personal Data is Processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

We use appropriate technical and organizational measures to protect the Personal Data that We collect and Process. The measures We use are designed to provide a level of security appropriate to the risk of Processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us using the contact details provided under clause 11.

6.1 We retain Personal Data collected where an ongoing legitimate business requires retention of such Personal Data.

6.2 In the absence of a need to retain Personal Data under clause 6.1 above, We will either delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and isolate it from any further processing until deletion is possible.

You are entitled to the following rights:
7.1 You can request Us for access and correction of Your Personal Data.
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7.2 If We have collected and processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect Processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

7.3 You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority as specified by the applicable data protection laws. 

7.4 You have the right to opt-out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “Manage Preferences” link in the marketing e-mails We send You. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact Us.

7.5 If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights:
7.5.1 You can request Us for deletion and erasure of Your Personal Data.
7.5.2 You can object to the Processing of Your Personal Data, ask Us to restrict Processing of Your Personal Data or request portability of Your Personal Data.

7.6 If You seek to exercise Your rights under this clause, please contact Us at the details provided in clause 11. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

8.1 Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customise the Website(s) for You or to make advertising messages more relevant to You.

8.2 Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

8.3 Analytics, Customisation and Advertising Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

8.4 When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

We recognize the importance of children's safety and privacy. We do not request, or knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to Us at the email address provided in clause 11.

10.1 SuprSend is intended for use by enterprises. Except for the Personal Data collected from You for the purposes mentioned under clause 2, this Policy is not applicable to Our Processing of any Personal Data transmitted by the Customer. We may receive Subscriber’s Personal Data as a part of the Service Data for which We will only act as a Processor and such Processing will be governed by the Terms. In such a case, the Subscriber’s data privacy questions and requests should be submitted to the Customer in its capacity as a Controller. We are not responsible for Customers’ privacy or security practices which may be different from this notice. Customers of SuprSend are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of SuprSend by the Customer or the Users.

10.2 When You log on to SuprSend using the online sign-on services, the social network platform may provide Us with access to certain information that You have provided them, The collection, use, and disclosure of Your Personal Data by these social networks shall be governed by the policies of such social networks and We shall have no liability or responsibility over their actions. 

10.3 Our Website(s) contain links to other Websites. Our Policy applies only to Our Website(s), so if You click on a link to another Website, You should read their privacy policy. We encourage You to review the privacy statements of any such other Websites to understand their Personal Data practices.

11.1 You may contact Us if You have any enquiries or feedback on Our data protection policies and procedures, or if You wish to make any request, in the following manner:
Kind Attention: SUPRSTACK INC
Email Address: support[at]suprsend[dot]com

Please come back and check for any updates to this Policy. If there are any material changes to this Policy We shall notify You or shall post a notice of the update on Our Website.