Privacy Policy
Last Updated: May 11th, 2023
SuperLink LLC (collectively, "Company", "we", "us" , or "our" ) takes data privacy and security seriously and believe in transparency. PLEASE CAREFULLY REVIEW this privacy policy ("Policy") that describes how we collect, use, share, and protect Personal Data that we collect from individuals who use, access or interact with our Business Operations (as defined below)(such individuals are collectively referred as "User", "you" or "your" ).
PLEASE NOTE: This Policy does not apply to our HR-related data collection practices, where you act as our job applicant, employee, independent contractor, corporate officer. A separate HR-related privacy policy will be made available to you in that case.
BY ACCESSING AND USING SUPERLINK OR ENGAGING IN COMMUNICATIONS WITH US, YOU CONSENT TO BE BOUND BY THIS POLICY AND AGREE TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL INFORMATION FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, YOU SHOULD NOT ACCESS SUPERLINK OR INTERACT WITH US IN ANY MANNER. Capitalized terms not defined herein shall have the meaning provided in the Terms of Service.
What is In Scope for this Privacy Policy
This Policy applies to the following:
WHAT INFORMATION WE MAY COLLECT. We want you to be in the know and provide additional information in Section 2 of this Policy. We may collect your Personal Data through:
"SuperLink", which refers to https://superlink.io/ or any services provided therein, including mobile applications, sub-domains, clickable URL, and websites with a link to this Policy or Terms of Service."
Your "General Interactions" with us, which refers to an individual that requests information from or makes general inquiries to us, provides services to us on behalf of their employers or interact with us via business-to-business contacts, attends in-person or virtual conferences hosted by us, requests or receives our marketing information, or where an individual’s images, videos or voices are used by us in marketing.
(collectively, our "Business Operations").
HOW WE TREAT THE PERSONAL INFORMATION WE COLLECT. No surprises. Please refer to Sections 3-7 of this Policy for more information.
WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. You can take control of how your Personal Data is used and shared according to Section 8 of this Policy.
International Data Transfers
Our Business Operations, including SuperLink, are housed on servers in the United States. If you are located outside of the United States, please be aware that information and data we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws and principles, including your data subject rights, may not offer the same level of protection as those in the country/region where you reside or of which you are a citizen. For more details, please refer toSection 10 (International Data Transfers).
Table of Content
| ⦁ Introduction | ⦁ What Personal Data We May Collect |
| ⦁ How We May Use Your Information | ⦁ How We May Share or Disclose Your Information |
| ⦁ How We Protect Your Personal Data | ⦁ Accessing, Updating, or Deleting Personal Data |
| ⦁ Data Retention and Deletion | ⦁ Your Control over Receiving Communications |
| ⦁ Children’s Privacy | ⦁ International Data Transfers |
| ⦁ Third Party Websites and Links | ⦁ Updates to this Privacy Policy |
| ⦁ How to Contact Us | ⦁ Other Addendum |
⦁ Introduction
.We want you to be in the know. Here is what we cover under this Policy.
What is "Personal Data"? "Personal Data" means information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, contact information, email address, phone number, device IDs, certain network identifiers, and other categories described below.
We may de-identify, aggregate, and/or anonymize your Personal Data by excluding and removing data components (such as your name, email address, or linkable tracking ID) through obfuscation, or through other means so that the resulting dataset is no longer personally identifiable to you (such resulting dataset is known as "Aggregated Data" ). Our use of Aggregated Data is not subject to this Policy.
⦁ What Personal Data We May Collect
We need your Personal Data to provide you a dynamic experience on SuperLink.
In order to provide SuperLink to you, and through your use of SuperLink, we may request you provide us with certain Personal Data. We will indicate on the form whether a particular field of Personal Data is mandatory or optional. If you choose not to provide certain Personal Data, we may not be able to make SuperLink available to you. Personal Data you provide to us through SuperLink or otherwise includes:
2.1 Categories of Personal Data We May Collect
| Categories | Types of Data |
|---|---|
| Contact Data | ⦁ Such as your first and last name, email address(es), and phone number. |
| Device Data | ⦁ Such as information that is automatically assigned to your devices used to access SuperLink, and our computers identify your Device by its Device Identifier, including IP address, unique device identifier (UDID), or other unique identifier(s). |
| Geolocation Data | ⦁ Approximate location based on your internet protocol (IP address), to the extent a User chooses to share such information with us. |
| Profile Data | ⦁ Such as your username and password that you may set to establish an Account with us and any Content uploaded to SuperLink (such as text, images, audio, and video, along with the metadata associated with the files you upload, which are further defined in the Terms of Service ). |
| Registration Data | ⦁ Such as information that may be related to your Account on SuperLink, or an event you register for. |
| Feedback | Such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online. |
| Transaction Data | Such as information about payments from you for products or Content you have purchased through SuperLink, and your financial information to compensate you for your Content, in connection with facilitating the processes so that you are rewarded for your creative Contents available to other Users (as further described in the Section 14 (Service Addendum) of our Terms of Service) , Note that we do not store your credit card information (credit card number, name on card, security code, expiration date, and CVV), but our payment processor may store your Payment Information for the purpose of facilitating payment. |
| Usage Data | Such as information about how you use SuperLink and interact with us, including information associated with any Content you upload to SuperLink or otherwise submit to us, information you provide when you use any interactive features of SuperLink, the URLs that referred you to SuperLink, and the areas within SuperLink that you visit and your activities there. Based on the Usage Data and other data categories we collect through SuperLink, we may draw inference regarding a User’s attributes, behavior and/or preference. |
| Social Network Data | We may collect Personal Data from your profile on a third-party social network, such as Facebook/Meta, Instagram, Twitter, LinkedIn and other networks (each, a "Linked Social Media Platform"), if you choose to connect with us through such Linked Social Media Platform. The Personal Data we may collect includes, but is not limited to, your name, username, and email address. In addition, SuperLink may offer features that will allow you to share information to and from a Linked Social Media Platform, including your age, date of birth, gender, or and proof of identification (to the extent such data is made available to us by such Linked Social Media Platform in accordance with its privacy policy). If you decide to use such features, you should check the privacy policy of each Linked Social Media Platform before using such features. |
| Marketing Data | We may collect your Personal Data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications. You may opt out from marketing emails in accordance with Section 8 (Your Control over Receiving Marketing Communication). |
| Information From Creators | If you are a Creator, we may collect your name, image, contact information, and professional profiles (in addition to other data categories identified in this Table), to facilitate delivery of SuperLink and/or your Content to other Users. We may also collect additional information relating to your social media account(s), age (verify 18+), and a W9 from all Creators who want to create an Account on SuperLink, in order to compensate you for your Content and other interactions with your Fans. |
| Personal Data from Third Party Sources | We may access or collect Personal Data from a third party when one user sends someone else a communication from SuperLink, such as an invitation or a gift to a friend, the information we receive from such User (e.g., names, email addresses, mobile number, etc.) will be used to facilitate the communication. We require each SuperLink User to ensure that s/he has the recipient’s permission to use his or her Personal Data for this purpose. When a User uses any "Referral" or "Send-a-friend" functionality made available by SuperLink, your email address, mobile number, name or username and message may be included in the communication sent to your addressee(s). |
| Other Information | Other Personal Data we may collect which is not specifically listed here, but which we will use in accordance with this Policy or as otherwise disclosed at the time of collection. |
2.2 Sources of Personal Data We May Collect
Personal Data You Provide Directly to Us. We may collect information about you when you provide it to us directly, including Account registration, completing surveys, questionnaires, or other webforms, or otherwise directly interacting with us with questions, feedback, or reports.
Personal Data We Automatically Collect from You. We may collect Personal Data about you through cookies and other similar tracking technologies. If you choose to disable such tracking technologies, some areas and features of SuperLink may not work properly. The information we collect from you via SuperLink depends on the settings of your device(s) and/or browsers. We recommend checking the polices and instructions of your device manufacturer(s) or browser provider(s) to learn what information they make available to us.
Personal Data We Collect from Third Parties. We may collect your Personal Data from the following sources:
Public records
Service Providers, who collect data on our behalf;
Advertising Partners, who assist us with marketing or promotional services related to how you interact with SuperLink;
Linked Social Media Platforms, if you choose to connect with us through your social media accounts.
⦁ How We May Use Personal Data
We may use your Personal Data for various business or commercial purposes, which are outlined below.
Our use of your Personal Data generally fall under the following categories:
⦁ Provide and Improve SuperLink, including:
Manage your Account, including providing support and assistance to you,
Process orders, billing, and complete payments, donations, and other transactions,
Conduct product research and development, including testing, analyzing, and improving SuperLink and our Business Operations,
Facilitate a Fan’s purchase of certain Contents, direct messages to Creators, make donations, and interact with other Users,
Manage accounting records, analyze financial results, comply with internal audit requirements, obtain and maintain insurance coverage, manage risks, or obtain professional advice, and other activities relating to our Business Operations.
Communicate with You and Conduct Marketing Outreach, including
Respond to your feedback, requests, questions, or inquiries,
Marketing our new features, products and services offered by us or through SuperLink,
Communicate with you about the product or services offered by other Users that you follow or interact with,
Conduct marketing outreach on behalf of ourselves, and/or our business partners via emails, push notification, or SMS messages. You can opt out at any time by following steps outlined in Section 8 of this Policy,
Personalize SuperLink, Content and communications based on your preferences.
Respond to your feedback, requests, questions, or inquiries,
⦁ Analytics and Performance. We use your Personal Data to create Aggregated Data, measure performance, and analyze key metrics relevant to our business, including the effectiveness of our marketing and advertising campaign, trend and business analysis.
⦁ Protect ourselves, our Users and Others, including
Protect our rights in connection with Business Operations,
Fulfill our legal obligations, including preventing and investigating illegal activities,
Ensure the privacy and security of SuperLink,
Detect fraud and prevent loss,
Protect the rights, property, or safety of you, SuperLink, or other parties,
Enforce this Policy and our Terms of Service.
⦁ Other purposes related to the reasons for which you provided Personal Data to SuperLink, and any other purposes with your consent, including those business purposes authorized by applicable privacy laws, such as the California Private Rights Act of 2020.
⦁ How We May Share or Disclose Personal Data
We will not share Personal Data without your consent, except as otherwise set forth in this Policy.
This section describes to whom we share or disclose Personal Data and the purposes for disclosure:
| Categories | Types of Data |
|---|---|
| Corporate Affiliates | We may disclose your Personal Data to our corporate subsidiaries and affiliates and with their respective officers, directors, employees, and agents in order to provide and improve SuperLink, and for approved marketing purposes. |
| Vendors, Business Partners | We engage third party vendors, contractors, or business partners to assist us in the day-to-day business or commercial operations and to perform services on our behalf, including processing transactions. We take commercially reasonable steps to ensure our third party vendors, contractors, or business partners provide at least the same level of protection for Personal Data as we do. |
| Companies Involved in Mergers and Acquisitions Transactions | If we sell or otherwise transfer part or the whole of our business or assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any Personal Data collected through SuperLink may be among the items sold or transferred. |
| Professional Advisors | We may share your Personal Data with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf. |
| Law Enforcement, Government Agencies, and Courts | We may disclose Personal Data at the request of laws enforcement or government agencies; in response to subpoenas, court orders, or other legal processes; to establish, protect, or exercise our rights; to defend against a legal claim; to detect, investigate, prevent, or take action against illegal activities or potential threats to the rights, property, or safety of any other person; or as otherwise required by laws. |
| Disclosures with Consent | We may ask, from time to time, if you would like us to share your information with affiliated or unaffiliated third parties. We will only disclose your information in this context with your consent. |
| Other Users | When you create an Account and upload content using SuperLink, the information contained in your public profile and the content displayed on or uploaded to SuperLink (including a User’s image, audio recording, and video captured) may be viewable to other Users through SuperLink, to the extent these other Users are given access to your profile and Content based on your Account settings. You may change your settings at any time. |
⦁ How We Protect Your Personal Data
We do our best to protect your information and ask that you work with us to keep it confidential, safe, and secure.
We use commercially reasonable security measures within SuperLink to help secure and protect Personal Data from unauthorized access or acquisition, such as industry-standard encryption technology. Despite our efforts to store Personal Data in a secure environment, we cannot guarantee the security of Personal Data during its transmission or its storage. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third parties, such as hackers, from illegally obtaining access to Personal Data. We do not represent or warrant that Personal Data about you will be protected against loss, misuse, or alteration by third parties. The safety and security of your Personal Data also depends upon you. When you use a password for access to restricted parts of SuperLink, you are responsible for keeping your password confidential. Do not share your password with anyone.
⦁ Accessing, Updating, or Deleting Personal Data
Your Account settings put you in control of how you manage certain Personal Data.
You may use your Account to access or correct the information that you provided to us, or is associated with your Account, by logging onto your Account through SuperLink. You may also request to access, correct, or delete your Personal Data by submitting a request via the contact information listed in "How to Contact Us" section below. We will promptly review all such requests in accordance with applicable laws. In certain circumstances, we may not be able to completely remove your Personal Data from our systems, as further discussed in Section 7 (Data Retention and Deletion).
⦁ Data Retention and Deletion
Nothing is forever. We have a few rules on how we retain your data.
We take reasonable steps to delete the Personal Data we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your Personal Data, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your Personal Data if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Data is contrary to our legal obligations or business objectives. When we delete your Personal Data, it will be removed from our active servers and databases; however, it may remain in our archives when it is not practical or possible to delete it.
⦁ Your Control over Receiving Communications.
Here are a few ways that you can control how we interact with you.
Email Communications: To provide you with information regarding SuperLink or our other products or offerings, we may send you promotional materials or other information via email ("Email Communications"). You may choose to stop receiving Email Communications by clicking on the "Unsubscribe" link located at the bottom of any email we send to you. Please note that certain Email Communications that are transactional in nature (for example, emails about your order, or a change in terms and features of your Account) may not contain an unsubscribe link or opt-out instructions.
Text Messages (SMS): We ask for your consent to receive text messages (including, messages with another Users, updates to SuperLink, or our other products or services that you may be interested in), which may be sent by automated systems or technology. You may unsubscribe from marketing text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. For additional information, please review our Terms of Service.
Push Notifications or Other Notifications Generated Through Your SuperLink Account: You may also adjust your mobile application’s settings or your Account settings to unsubscribe from push notification or other communications generated through your Account on SuperLink.
⦁ Children’s Privacy
Only individuals over the age of 18 may use SuperLink.
No part of SuperLink is directed to children under the age of 18, and no one under the age of 18 may access, browse, or use SuperLink or provide any information to or on SuperLink. Consequently, we do not knowingly collect or directly solicit Personal Data from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Data about yourself to us through SuperLink or offline. If we learn that we have collected Personal Data from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Data, please contact us by following instructions at the "How to Contact Us" section below.
⦁ International Data Transfer
We may transfer, or otherwise make available Personal Data that we collect from you outside of your home jurisdiction.
We may transfer, or otherwise make available Personal Data that we collect from you to countries outside of your home jurisdiction where we or our service providers and business partners operate. Some of these jurisdictions may not have the same data protection laws as your home jurisdiction. We will comply with applicable legal requirements when transferring Personal Data to countries other than the country where you are located. If you are located in the EEA, UK, or Switzerland, we will transfer your Personal Data in accordance with adequacy decisions, standard contractual clauses, or other data transfer mechanisms compliant with applicable laws. When we transfer your Personal Data to other countries, we will protect your Personal Data in accordance with this Policy or as otherwise disclosed to you. By using SuperLink or otherwise interact with our Business Operations, or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.
When storing, hosting, or otherwise processing your information (including Personal Data), we may send such data outside of the EEA, UK, or Switzerland. When we transfer information to other countries, we do so for the purposes set forth in this Policy and in accordance with applicable laws. We rely on recognized legal basis to lawfully conduct cross-border/international transfers of Personal Data outside of the EEA, UK, or Switzerland, such as (i) your express informed consent to do so (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between us and you, (ii) for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person, or (iii) where the transfer is subject to safeguards that provide for the protection of your Personal Data, such as standard contractual clauses or other measures approved by the competent data protection authorities for the protection of Personal Data when transferred to a third country. You may request such details by following instructions at the "How to Contact Us" section below.
⦁ Third Party Websites and Links
This Policy does not apply to any third-party websites or applications.
SuperLink may contain links to websites, mobile applications or services operated and maintained by third parties. These links are connected to external websites and third parties that have their own privacy policies. If you follow any links that direct you away from SuperLink, including links to social media sites, our payment processors, or to other websites, this Policy will not apply to your activities on the other sites you visit.
We are not responsible for the practices employed by these third party sites, including the information or content, and cannot guarantee the adequacy of the privacy and security practices employed by these third party sites. A link to a third party’s website should not be construed as an endorsement. We encourage you to investigate and ask questions before disclosing Personal Data to third parties.
⦁ Updates to This Policy
We may modify or update this Policy from time to time.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using SuperLink and from time to time, so that you are aware of any changes. If we make a change to this Policy that, in our sole discretion, is material, we will notify you as appropriate under the circumstances. Unless otherwise indicated, any changes to this Policy will apply immediately upon posting to SuperLink. In all cases, your use of SuperLink after "Last Updated" date listed on this Policy indicates your acceptance to the modified or updated Policy and your continued consent to our processing of your Personal Data according to the terms of the then-current Policy.
⦁ How to Contact Us
If you have any questions or concerns about this Policy, please contact us at:
SuperLink LLC
Attn: Privacy Officer
9800 Wilshire Boulevard, Suite 206
Beverly Hills, CA 90212
hello@superlink.ioOTHER ADDENDUM: STATE PRIVACY RIGHTS
As of the "Last Updated" date, our Business Operations are not subject to state privacy laws referenced in this Addendum.
California Privacy Rights. If you are a California resident, you have the right to request certain information regarding the collection, use for business purposes, and disclosure of personal information by certain businesses governed by the California Privacy Rights Act of 2020 (CPRA) and its implementing regulations (collectively, "California Privacy Laws" ). You may find information regarding business entities governed by the California Privacy Laws, the applicability of California Privacy Laws, and California consumers’ privacy rights, and other related information in greater details at:
https://oag.ca.gov/privacy/ccpa#:~:text=The%20CCPA%20requires%20business%20privacy,the%20Right%20to%20Non%2DDiscrimination.
Other State Privacy Rights: We closely monitor our data collection practices based on the requirements set forth in other state privacy laws, including those in Virginia, Colorado, Utah, Connecticut, Iowa, Indiana, Montana, and Tennessee. To the extent any state privacy laws apply following consultation with our privacy compliance advisors, we will exercise commercially reasonable efforts to update this Policy.