Our privacy policy

Effective: August 20, 2021

‍This Privacy Policy describes how SuperCircle collects, uses and discloses information and what choices you have with respect to the information.
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Table of Contents

• Applicability of this Privacy Policy
• Information We Collect and Receive
• How We Use Information
  
• Data Retention
  
• How We Share and Disclose Information
• Security
• Age Limitations
• Changes to this Privacy Policy
• International Data Transfers
• Your Rights
• California Privacy Rights
• Contacting Us

Applicability Of This Privacy Policy

This Privacy Policy applies to SuperCircle’s tools and platform, including the associated SuperCircle mobile and desktop applications (collectively, the “Services”), supercircle.ai and other SuperCircle websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with SuperCircle. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of SuperCircle’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the SuperCircle platform (“Third-Party Services”), or any other third-party products, services or businesses.

The delivery, access and use of the Services, are governed by a separate agreement (the “Customer Agreement”) entered into by the person, organization or other authority that controls the subscription to the Services (the “Customer”).

Information We Collect And Receive

SuperCircle may collect and receive messages, files or other content submitted through Services accounts (collectively, “Customer Data”) and other information and data (“Other Information”) in a variety of ways:

• Customer Data. Customers or individuals granted access to the Services by a Customer (“Authorized Users”) submit Customer Data to SuperCircle when using the Services.
• Other Information. SuperCircle also collects, generates and/or receives Other Information:
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  1. Account information. To create or update an account, you or the Customer supply SuperCircle with an email address, phone number, password, domain and/or other details. In addition, Customers may provide SuperCircle (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
  
  2. Usage information.
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  - Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users use the Services.
  
  - Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  
  - Device information. SuperCircle collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
  
  - Location information. We receive information from you, the Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted or an IP address received from your browser or device to determine approximate location. SuperCircle may also collect location information from devices in accordance with the consent process provided by your device.
  
  3. Cookie information. SuperCircle uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out opportunities and other options, please see our Cookie Policy.
  
  4. Contact information. In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import (such as an address book from a device or API) is collected when using the Services.
  
  5. Third-Party data. SuperCircle may receive data about organizations, industries, lists of companies that are customers, users, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
  
  6. Additional information provided to SuperCircle. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by SuperCircle or a vendor, request support, interact with our social media accounts or otherwise communicate with SuperCircle.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as account setup details, is not provided, we may be unable to provide the Services.

How We Use Information

SuperCircle uses Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, SuperCircle uses Information:

• To provide, update, maintain and protect our Services, Websites and business. This includes use of Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.‍
• As required by applicable law, legal process or regulation.
• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Information to respond.‍
• To develop and provide additional features. SuperCircle tries to make the Services as useful as possible for Authorized Users. For example, we may use Information to customize a Services experience, or create new or improved features and products.‍
• To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security notices. These communications are considered part of the Services and you can generally not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about SuperCircle. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from SuperCircle please get in touch through the contact mechanisms described below.
• For billing, account management and other administrative matters. SuperCircle may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues and abuse.
  

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, SuperCircle may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data”.

Data Retention

SuperCircle may retain Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Information after you have deactivated your account for the period of time needed for SuperCircle to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share And Disclose Information

SuperCircle may retain Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Information after you have deactivated your account for the period of time needed for SuperCircle to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Use Information

This section describes how SuperCircle may share and disclose Information, as described in the section entitled 'Information We Collect and Receive' above.

• The Customer’s Instructions. SuperCircle may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process.
• Displaying the Services. When an Authorized User submits Information, it may be displayed to other Authorized Users using the Services. For example, an Authorized User’s name may be displayed with their profile to other Authorized Users.
• Collaborating with Others. The Services provide different ways for Authorized Users to collaborate. Information, such as an Authorized User’s profile Information, may be shared.
• Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, the Customer using Service features to export logs of activity.
• Third-Party Service Providers and Partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers.
• Corporate Affiliates. SuperCircle may share Information with its corporate affiliates, parents and/or subsidiaries.
• During a Change to SuperCircle’s Business. If SuperCircle engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of SuperCircle’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data. We may disclose or use aggregated or deidentified Information for any purpose. For example, we may share aggregated or deidentified Information with prospects or partners for business or research
• To Comply with Laws. If we receive a request for information, we may disclose Information if we believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of SuperCircle, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
• With Consent. SuperCircle may share Information with third parties when we have consent to do so. SuperCircle may share Information with consent of the primary owner of such account or, where relevant, authorized corporate or other officer.

Security

SuperCircle seeks to protect Information you provide from loss, misuse, and unauthorized access or disclosure. Given the nature of communications and information processing technology, SuperCircle, like all leading software providers, cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. In addition, when you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age Limitations

To the extent prohibited by applicable law, SuperCircle does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes To This Privacy Policy

SuperCircle may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, SuperCircle will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account.

International Data Transfers

SuperCircle may transfer your Personal Data to countries other than the one in which you live. To the extent that Personal Data is transferred abroad, SuperCircle will seek compliance with the requirements of the applicable laws in the respective jurisdiction in line with SuperCircle’s obligations.

For example, we offer the following safeguards if SuperCircle transfers Personal Data from jurisdictions with differing data protection laws:

• European Union Model Clauses. SuperCircle offers European Union Model Clauses (“Model Clauses”) also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the EEA, Switzerland and the UK and for other international transfers of Customer Data as relevant.
• Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System And Privacy Recognition For Processors. SuperCircle’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal data transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal data controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here.

Your Rights

Individuals across the globe, including the European Economic Area, the United Kingdom and Brazil, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information.

To the extent that SuperCircle’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws covering the processing of Personal Data such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), SuperCircle relies on its legitimate interests, described above, to process your data. SuperCircle may also process Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to SuperCircle’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We Collect And Receive section above. We collect this information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How We Share and Disclose Information section above. Please note that we may use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at hello@supercircle.ai. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Contacting SuperCircle

When we refer to SuperCircle, we mean the following entity: Friendlybuzz Company, PBC.

Please feel free to contact SuperCircle if you have any questions about this Privacy Policy or SuperCircle’s practices, or if you are seeking to exercise any of your statutory rights. SuperCircle will respond within a reasonable timeframe. You may contact us at hello@supercircle.ai.