Privacy Policy

Last Updated: September 3rd, 2024

SuperLink LLC (collectively, "Company", "we", "us", or "our") takes data privacy and security seriously and believes 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 DATA 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 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, engages with us through our social media pages, or where an individual's images, videos or voices are used by us in marketing.

(collectively, our "Business Operations").

HOW WE TREAT THE PERSONAL DATA 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.

U.S. Data Storage

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 to Section 10 (International Data Transfers) and Section 14 (EU/EEA/UK Addendum).

1. Introduction

2. What Personal Data We May Collect

3. How We May Use Your Information

4. How We May Share or Disclose Your Information

5. How We Protect Your Personal Data

6. Accessing, Updating, or Deleting Personal Data

7. Data Retention and Deletion

8. Your Control over Receiving Communications

9. Children's Privacy

10. International Data Transfers

11. Third Party Websites and Links

12. Updates to this Policy

13. How to Contact Us

14. Privacy Terms for specific Jurisdictions

15. Cookies and Similar Technologies

Section 1. 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 and may include Sensitive Personal Data to the extent you voluntarily share with another User via SuperLink.

Sensitive Personal Data means Personal Data regarding a User's:

government-issued IDs, Social Security numbers, or other national identity numbers or documents;
financial account information, including bank account, debit card, and/or credit card details;
precise geolocation or other identifying information relating to a User's specific locations that are considered private;
username or email address in combination with a password or security question and answer that would permit access to an online account;
other sensitive information, including biometric data, health insurance information, medical information regarding medical history, medical treatment, mental or physical condition, or medical records.

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.

Section 2. 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:

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 and other Payment Methods 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. Note that we do not store your credit card information (credit card number, name on card, security code, expiration date, and CVV) ("Payment Information"), 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 or other Users, including information associated with any Content you upload to SuperLink or otherwise submit to us, information about your use of or access to SuperLink (including enrollment and use of certain Revenue Programs) 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, user ID associated with your social media account, 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 You Provide When Interacting with other Users

We may collect information about you when you interact with other Users of the SuperLink community including, but not limited to, comments, Direct Messaging, reactions, chats, and other Interaction Content.

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 interact with us through your social media accounts

Section 3. How We May Use Personal Data

We may use your Personal Data for various business or commercial purposes, which are outlined below.

Provide and Improve SuperLink

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 User's purchase of certain Contents, direct messages to or video appointments with 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

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

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

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

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.

Section 4. How We May Share or Disclose Personal Data

Category	Context
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.
Service Provider, 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 law 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.

Section 5. How We Protect Your Personal Data

We recognize the importance of protecting your information and ask that you work with us to keep it confidential, safe, and secure.

We endeavor to use and maintain commercially reasonable physical, technical, and organizational security measures within SuperLink to help protect Personal Data from unauthorized access, acquisition, use, alteration, or accidental loss.

Despite our efforts to store and protect Personal Data in a secure environment, no security system is perfect. We cannot guarantee the security of Personal Data during its transmission or its storage. 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.

Section 6. 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).

Section 7. Data Retention

Nothing is forever. We have a few rules on how we retain your data.

We will retain your Personal Data only for as long as necessary to fulfil the purposes for which we collected and processed your Personal Data, to make SuperLink available to our Users, or as required by applicable laws or other regulatory, accounting or reporting requirements.

We take reasonable steps to delete the Personal Data we collect when:

we have a legal obligation to do so,
we no longer have a purpose for retaining the information, or
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.

Section 8. 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.

Section 9. 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.

Section 10. International Data Transfers

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.

Section 11. 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, including without limitation, our payment process, Stripe, Inc. ("Stripe") subject to Stripe's privacy policy and terms of service; and our video conferencing provider, Zoom Video Communications, Inc. subject to Zoom's privacy policy and terms of use.

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.

Section 12. 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 the "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.

Section 13. 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.io

Section 14. Privacy Terms for Specific Jurisdictions

As of the "Last Updated" date, our Business Operations are not subject to state privacy laws referenced in this Addendum.

A. State Laws in the United States

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

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.

B. Other Jurisdictions

This addendum of the Policy applies only if you access SuperLink from a country that is a Member State of the European Union or European Economic Area (collectively, "EU"), the United Kingdom ("UK"), or Switzerland, and it supplements the information in the remainder of our Policy, above.

Section 15. Cookies and Similar Technologies

Your browsing activities and other use of SuperLink are monitored by Cookies and other tools.

BY VISITING AND/OR USING SUPERLINK, YOU HEREBY CONSENT TO THE USE OF COOKIES AND/OR OTHER SIMILAR TECHNOLOGIES, THE COLLECTION OF YOUR USAGE DATA BY SUPERLINK, AND IF APPLICABLE, ANY RECORDING OF YOUR EXPERIENCE ON SUPERLINK BEING ACCESSED, COLLECTED, STORED, AND OTHERWISE PROCESSED BY SUPERLINK, AND OUR THIRD-PARTY SERVICE PROVIDERS AS SET FORTH IN THIS POLICY.

What is a Cookie:

A "cookie" is a small file created by a web server that can be stored on your device (if you allow). "Session" cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. "Persistent" or "permanent" cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or "flash" cookies) are used to collect and store information about your preferences and navigation to, from, and on a website.

Cookie Types and Their Uses

Type of Cookies	Description
Essential cookies	Required cookies enable you to navigate SuperLink and use its features. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into SuperLink, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into SuperLink and to process your online transactions and requests.
Functionality cookies	Functionality cookies allow SuperLink to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of SuperLink after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on SuperLink to personalize your visit.
Performance cookies	These cookies collect information about how you use SuperLink, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how SuperLink functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit SuperLink. We may also utilize Flash cookies for these purposes.
Marketing cookies	Marketing Cookies deliver advertisements ("ads") that may be more relevant to you and your interests. They may be 1st party cookies or 3rd party cookies placed by us, by our service providers on our behalf, or by third party business partners with our permission. We, our service providers, or our business partners may use targeting or advertising cookies to track how you visit SuperLink, browse pages on SuperLink, and click on certain links. These cookies help measure the effectiveness of our advertising campaigns. We may also allow our third party business partners to use targeting or advertising cookies on the services for similar purposes, including collecting information about your online activities over time and across different websites. They also perform functions, such as preventing the same ads from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting ads that are based on your interests.

Other Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.), HTML Local Storage, Social Widgets, or UTM Codes that we may use to collect data as Users navigate through and interact with SuperLink.

Web Beacons:

Web beacons (or Web bugs) are small strings of code that enable delivery of a graphic image on a webpage for the purpose of transferring data. When corresponding with you via HTML capable email, Web beacons and similar technologies let us know whether you received and opened our email.

Tracking-Pixels:

A tracking pixel is a small piece of code we may use to collect and share with online advertisers' information on your usage of SuperLink. Through the tracking pixels, we can ensure that we are serving ads that match your interests when you are visiting any online advertisers' websites.

Social Widgets:

These are buttons or icons provided by social media platforms that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.

UTM Codes:

These are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

Third-party cookies or tracking technologies used on SuperLink may include:

Google Analytics:

We may use Google Analytics to collect and process data about your use of SuperLink. For more information, visit:

Google Marketing:

We may use Google's marketing technologies to track user activity and provide personalized advertisements. For more information, visit:

TikTok cookies:

We may use TikTok cookies to track the effectiveness of our ads and optimize performance. For more information, visit:

Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising.

If you decline the use of cookies, you may not have access to the full benefits of SuperLink. Further, your opt-out only applies to the web browser you use, so you must opt out of each web browser on each computer you use.