SUPLARI, INC. PRIVACY POLICY

 

Last Updated: 7/20/2021

This Privacy Policy explains how Suplari, Inc. (“Suplari,” “we,” “our” or “us”) collects, uses, and discloses information about you as a controller of your personal data. This Privacy Policy applies when you use our websites, applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, apply for a position on the website, or otherwise interact with us. This Privacy Policy does not apply in circumstances where Suplari is acting as a processor for the data our customers provide to Suplari as a part of our service license agreements for our SaaS offering. In those circumstances, Suplari’s customers are the controllers of personal data they provide to use for processing.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS
Collection of Information
Use of Information
Sharing of Information
Analytics
How We Protect Your Personal Data
Do Not Track Notice
Links to Third Party Websites
Children
Transfer of Information to the United States and Other Countries
Your Choices
Additional Disclosures for Individuals in Europe
Contact Us


COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you create an account, apply for a position, visit and provide information to us on this website, request customer support, or otherwise communicate with us regarding our Services. The types of personal data we may collect include your name, title, company name, email address, phone number, address, employment history, education, other information contained in your resume, and any other information you choose to provide.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

  • Device and Usage Information: We collect information about how you access our Services, including your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
  • Information Collected by Cookies and Similar Tracking Technologies: We use cookies and similar tracking technologies to track the activity on our website and to hold information. Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our website. Examples of cookies we use include:

Session Cookies. We use Session Cookies to operate our website.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Analytics Cookies. We use Analytics Cookies to learn more about the users of our website.
Security Cookies. We use Security Cookies for security purposes.
For more information about cookies and how to disable them, see the Your Choices section below.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior.


USE OF INFORMATION

We may use the information we collect to:

  • Provide, maintain, and improve our Services.
  • To consider your application for employment.
  • Notify you about changes to our website.
  • Allow you to participate in interactive features of our website when you choose to do so.
  • Provide customer care and support.
  • Obtain analysis or valuable information to improve our website.
  • Monitor the usage of our Services for the purpose of detecting, preventing, and addressing technical issues.
  • Communicate with you about our Services.
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Suplari and others.
  • Comply with our legal and financial obligations.
  • Carry out any other purpose described to you at the time the information was collected.
  • Restricted data processing: We use Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website.


SHARING OF INFORMATION

 We may share personal data in the following circumstances or as otherwise described in this policy:

  • We share personal data with vendors, service providers, and consultants that need access to personal data in order to perform services for us, such as companies that assist us with web hosting, technical support, fraud prevention, customer service, human resources, and marketing and advertising.
  • We may disclose personal data if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including to defend or prosecute legal claims and lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may share personal data if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Suplari, our users, the public, or others.
  • We share personal data with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal data in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • We share personal data with your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

 ANALYTICS

We allow others to provide analytics services on our behalf across the website. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications. This information may be used by Suplari and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.


HOW WE PROTECT YOUR PERSONAL DATA

We have implemented and maintain reasonable security procedures and practices, and commercially reasonable technical and organizational measures, to ensure a level of security appropriate to the risk in order to help protect your personal data from unauthorized access and exfiltration, theft, or disclosure.  However, no security system is perfect. We will notify you if there is a breach of our security where required by law or deemed necessary.


DO NOT TRACK NOTICE

This website does not currently support certain browser settings or otherwise respond to Do Not Track requests.


Links to Third Party Websites

Some portions of our website may contain links to other websites on the Internet that are neither under our control nor maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.


CHILDREN

This website is not intended for or directed at children under the age of 13. In addition, we do not knowingly collect personal data from children under the age of 13. Only adults 18 years or older are permitted to access this website and provide their personal data to us. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us below. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.


TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

 Suplari is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal data to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.


YOUR CHOICES

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving marketing and promotional emails from Suplari by following the instructions in those communications or by emailing us at compliance@suplari.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.


ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under the law when we process your personal data as a controller, as described below.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

  • To perform our responsibilities under our contract with you (e.g., providing the products and services you requested).
  • When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, consider your application for employment, and communicate with you).
  • To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
  • When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store your personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, email us at compliance@suplari.com.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html


CONTACT US

If you have any questions about this Privacy Policy, please contact us by email at compliance@suplari.com.  You can also contact Suplari’s Data Protection Officer, Chad Baker, at cbaker@suplari.com.