Suplery Inc. Privacy policy

Thank you for choosing Suplery!

Suplery Inc. ("Company", "we", "us", "our") are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this Privacy policy, or our practices with regards to your personal information, please contact us at hello@suplery.com.

When you visit our website https://suplery.com (the "Website"), use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy policy that you do not agree with, please discontinue use of our Services immediately.

This privacy policy applies to all information collected through our Services (which, as described above, includes our Website and App), as well as, any related services, sales, marketing or events.

Please read this privacy policy carefully as it will help you understand what we do with the information that we collect.

What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; job titles; passwords; contact preferences; contact or authentication data; billing addresses; and other similar information.

Payment Data. We may collect data necessary to process your payment if you make purchases. Payment processing is handled by our Payment processor (as defined in our Terms of service). Additional information about payment data handling is set out in the "Payment processing" section below.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called "How do we handle your social logins?" below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, Platform login, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, mouse clicks, scrolls, navigational behavior, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected through our App

In Short: We collect information regarding your geolocation, mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

• Geolocation Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features and data on your mobile device, including your camera, photo library (gallery), contacts, and other features. We request these permissions only to provide specific App features, as described below. You may grant, deny, or revoke any of these permissions at any time in your device's settings. Denying or revoking a permission may disable the related App feature but will not otherwise affect your access to the Services.
• Barcode Scanning (Camera and Photo Library). The App includes a barcode-scanning feature. When you use this feature, the App accesses your camera (to capture a live image of a barcode) or your photo library (when you select an existing image from which to read a barcode). Barcode decoding is performed entirely on your device using on-device libraries. The image — whether a live camera frame or an image selected from your photo library — is processed only in your device's memory, is never written to your device's storage by us, is never transmitted to our servers, and is never shared with any third party. Only the decoded barcode value is briefly transmitted to our servers, solely for the purpose of matching it to a product in our catalog. Once the matching product is identified, the barcode value is discarded. We do not retain barcode values, scan history, captured images, or any image-derived data on our servers in connection with this feature.
• Image and Attachment Uploads (Photo Library). Separately from barcode scanning, the App may allow you to upload images from your photo library to the Services — for example, to add product or inventory images, set a profile picture, or attach files to messages or support inquiries. Where you choose to upload an image, that image is transmitted to and stored on our servers and is processed in accordance with this Privacy policy. We access your photo library only at the moment you initiate an upload and only with respect to the file(s) you select. We do not scan, index, or otherwise access the rest of your photo library.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our App you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

Your control over device permissions and our limitations. You are solely responsible for managing the permissions you grant to the App through your device's operating system. We have no access to, and no control over, your camera, photo library, contacts, location, or other device features or data beyond the limited, feature-specific access expressly described in this Privacy policy. We are not responsible for any image, audio, location, or other data captured, retained, or transmitted by your device's operating system, your device manufacturer, third-party applications installed on your device, your device backups, or cloud services associated with your device, including without limitation any automatic photo backups, OS-level scan or screenshot features, or third-party keyboards, file pickers, or media managers. Our liability for any feature that depends on device permissions is limited as set forth in our Terms of service, including the disclaimer and limitations-of-liability sections therein.

Third-party analytics, error reporting, and advertising tools

In Short: We use third-party tools to understand how the Services are used, to detect and fix errors, and to measure marketing performance. Some of these tools are used for advertising and tracking purposes, and you can limit them through your cookie or tracking preferences.

The Website and the App incorporate third-party tools that fall into the following categories:

• Product and traffic analytics — to measure how the Services are used so that we can improve them.
• Session replay and usability diagnostics — to record interactions with the Website and the App so that we can diagnose usability issues. We configure these tools to mask sensitive inputs, including password fields and payment fields.
• Error and crash reporting — to capture diagnostic information when the Services encounter an error so that we can investigate and fix the issue.
• Marketing measurement and audience-building — to measure the performance of our advertising and to build advertising audiences. These tools are used for tracking and advertising purposes and may involve the sharing of information about your activity on the Services with the relevant providers for use across their own services and on other websites and apps.

These tools may collect information available within the browser or in-app environment, including: information you submit through forms (other than fields we mask); your interactions with the user interface; browser-level identifiers and cookies; technical information about your browser, operating system, and device; IP address; the URL or in-app screen you are viewing; and information about errors and crashes.

Tools used for marketing measurement and audience-building involve the sharing of personal information with third parties for advertising purposes. In some jurisdictions, this constitutes "sharing" or "selling" of personal information. Where applicable law (including the California Consumer Privacy Act / CPRA) gives you the right to opt out of such sharing or sale, you may exercise that right through our cookie consent / "Your Privacy Choices" controls and as described in the "Do California residents have specific privacy rights?" section. On Apple devices, where required by Apple's App Tracking Transparency framework, we will not enable advertising-tracking tools unless you have granted permission through the corresponding system prompt.

Because these tools rely on cookies and similar storage technologies, you can also limit or block their operation by using your browser's cookie controls or, in the App, by adjusting your cookie preferences. Blocking these tools will not prevent your use of the Services but may limit our ability to detect and fix errors that affect you.

We may add, replace, or remove third-party tools from time to time. The categories of providers with whom we share information are also described in the "Who will your information be shared with?" section.

Payment processing

In Short: Payments are processed by our Payment processor. We do not receive or store your full payment card data.

Payments made through the Services — including payments made through the App — are processed by our Payment processor (as defined in our Terms of service). When you enter payment information into the Services, that information is collected directly by the Payment processor. Your full payment card data is transmitted directly to the Payment processor and is not collected, processed, or stored on Suplery's servers.

When you save a payment method to your account, the Payment processor provides us with limited reference information about that payment method, which we store and associate with your account so that we can: (a) display a recognizable summary of your saved payment method; (b) initiate authorized charges, refunds, and payouts through the Payment processor; (c) detect and prevent fraud; and (d) comply with our legal, accounting, and tax obligations.

The Payment processor is independently responsible for the processing, storage, and security of your full payment card data. The identity of the Payment processor and a link to its privacy notice and applicable terms are set out in our Terms of service. For additional information about how we engage the Payment processor and other payment-related obligations between you and us, please review the relevant sections of our Terms of service, including any provisions on payment, payouts, refunds, chargebacks, and set-off.

We are not responsible for the acts, omissions, security, or privacy practices of the Payment processor or of your card issuer or bank.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name and email address. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

Health, medical, and fitness data

In Short: We do not collect health, medical, or fitness data, and the App does not access platform health APIs.

The Services are a business tool for beauty industry professionals to manage product inventory, supplier-client transactions, and related business operations. The Services are not a health, medical, wellness, or fitness application.

The App does not integrate with Apple HealthKit, Google Fit, Google Health Connect, or any equivalent platform health, medical, or fitness API. The App does not request, access, collect, store, or transmit health data, medical records, prescription data, treatment records, diagnostic information, fitness data, biometric identifiers, or wellness metrics about you, your employees, your clients, or any other person.

Some products listed in our catalog may belong to product categories that intersect with personal-care or cosmetics regulation (for example, sunscreens or topical cosmetics). Information that we collect about products — including barcode values, product identifiers, names, descriptions, ingredient lists, and inventory quantities — is product reference data and inventory data; it is not health information about any individual.

If you choose to enter free-text content into the Services (for example, internal product notes, inventory descriptions, or messages to suppliers), you are solely responsible for the content you enter. We ask that you do not enter health, medical, or other sensitive personal information about yourself or any third party (including your salon's clients) into the Services, and we do not solicit such information. To the extent any such information is nevertheless entered, it will be handled as ordinary user-generated content under this Privacy policy and our Terms of service, and we disclaim any liability for the entry of such content by you.

How do we use your information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "How do we handle your social logins?" for further information.
• To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at dataprotection@suplery.com and be sure to include your name, testimonial location, and contact information.
• To request feedback. We may use your information to request feedback and to contact you about your use of our Services.
• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
• To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).
• To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• To improve our services and for other business purposes. We may gather and aggregate all collected data to improve our services, optimize the user experience, and for other business purposes, such as analytics, troubleshooting, and development.

Will your information be shared with anyone?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Place API). To find out more about Google's Privacy Policy, please refer to this link: https://policies.google.com/privacy. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: company or drop-off points addresses for suppliers and ship address for clients; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled "How do we use your information?". We obtain and store on your device ('cache') your location for one (1) month. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein and Norway) or United Kingdom, please take a look at our Cookie Policy.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
• Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

Who will your information be shared with?

In Short: We only share information with the following categories of third parties.

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "How can you contact us about this policy?".

• Cloud Computing Services
• Data Storage Service Providers
• Order Fulfillment Service Providers
• Payment Processors
• Communication & Collaboration Tools
• Data Analytics Services
• Finance & Accounting Tools
• Sales & Marketing Tools
• Website Hosting Service Providers

Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy. Additional details about the third-party tools that rely on cookies and similar technologies are set out in the "Third-party analytics, error reporting, and advertising tools" section above.

How do we handle your social logins?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services may offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, profile picture as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "Will your information be shared with anyone?" above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

How long do we keep your information?

In Short: We retain your information only as long as we have a legitimate business or legal reason to do so. The periods listed below are maximum retention ceilings — not commitments to retain — and we may delete information sooner.

The periods set out in this section represent the maximum periods during which we may retain each category of information. They are not minimums and do not create any obligation on our part to retain information for any specific period. We may delete or anonymize information earlier in the ordinary course of our operations, in response to a verified deletion request, in accordance with our internal data-management practices, or where retention is no longer necessary for the purpose for which the information was collected. Where applicable law requires a longer minimum retention period for specific categories of information (for example, tax or accounting records), we will retain the affected information for the period required by law.

The maximum retention periods we may apply are as follows:

• Account information (name, email, business details, login credentials, contact information): up to six (6) years after account closure, in line with the confidentiality and account-deactivation provisions of our Terms of service.
• Order, invoice, payment, refund, payout, and tax records: up to seven (7) years following the relevant transaction, or such longer period as required by applicable U.S. tax, accounting, or commercial laws.
• User-uploaded images and attachments (product images, profile pictures, message attachments): for the duration of your account and up to the same maximum retention period as account information after account closure, unless you delete them earlier through the Services.
• Messaging and communication content between you and other users or between you and us: for the duration of your account and any period required by law or to resolve open disputes.
• Device, log, and usage data (IP address, device identifiers, browser, OS, activity logs): up to twenty-four (24) months, after which such data is deleted or anonymized. Aggregated or anonymized data that no longer identifies you may be retained indefinitely.
• Push notification tokens: until you disable notifications, uninstall the App, or our records show the token is no longer valid, plus a short technical retention period of up to ninety (90) days.
• Payment-method reference information provided by our Payment processor (described in "Payment processing" above): for as long as you maintain the saved payment method on your account, plus up to the same maximum retention period as Order and payment records after the payment method is removed or your account is closed.
• Barcode-scan data: scan images are not retained at all (they are processed in your device's memory and discarded). Decoded barcode values transmitted to our servers for product matching are deleted immediately after the matching product has been identified; we do not retain scan history or any image-derived data on our servers.
• Backup copies: where information is included in routine system backups, that information is retained for the duration of the backup rotation cycle (typically up to ninety (90) days) and is isolated from active processing.
• Information held by third-party processors and tool providers (described in "Third-party analytics, error reporting, and advertising tools" above): subject to the retention practices of the relevant provider, which we do not control.

When we no longer have a legitimate business or legal reason to retain your personal information, we will delete or anonymize it. Where immediate deletion is not technically feasible (for example, because the information is held in backup), we will isolate the information from active processing and delete it as part of our scheduled backup rotation.

How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dataprotection@suplery.com.

What are your privacy rights?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at privacy@suplery.com.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may access your account settings and update your preferences.

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

Do California residents have specific privacy rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA privacy policy

The California Code of Regulations defines a "resident" as:

1. every individual who is in the State of California for other than a temporary or transitory purpose and
2. every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents".

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Suplery Inc. collects and shares your personal information through:

• Social media cookies
• Beacons/Pixels/Tags

More information about our data collection and sharing practices can be found in this privacy policy.

You may contact us by email at ccpa@suplery.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

Suplery Inc. has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.
• Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.
• Category D. Commercial information, such as transaction information, purchase history, financial details and payment information.
• Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements.
• Category G. Geolocation data, such as device location.
• Category H. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.
• Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "Who will your information be shared with?".

Suplery Inc. has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Suplery Inc. will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• you may object to the processing of your personal data
• you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
• you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at ccpa@suplery.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Do we make updates to this policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy policy from time to time. When we do, we will publish the new version on suplery.com and update the "Last updated" date at the top of this Privacy policy. The updated version will be effective as soon as it is accessible. Previous versions of this Privacy policy are also available on suplery.com. We encourage you to review this Privacy policy periodically to stay informed of how we are protecting your information.

How can you contact us about this policy?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Adam Golovenko, by email at dataprotection@suplery.com, by phone at +1 (415) 715 9168, or by post to:

Suplery Inc. data protection officer Adam Golovenko, 3 Germay Dr., Unit 4-2932, Wilmington, DE, 19804, United States

How can you review, update, or delete the data we collect from you?

You may review, update, and delete personal information that we collect from you. Depending on your region, additional rights may apply as described in the "What are your privacy rights?" and "Do California residents have specific privacy rights?" sections above.

Reviewing and updating your information. You can review and update most of your personal information at any time in your account settings on the Website or in the App.

Deleting your account from within the App. If you registered or use a Suplery account through our mobile application, you can delete your account directly in the App at any time. Open the App and go to Settings → Company → Delete Company Account, then follow the on-screen instructions. Submitting an in-app deletion request triggers the same workflow as the email request described below.

Deleting your account or specific data by email. You may also request deletion of your account or of specific personal information at any time by emailing us at hello@suplery.com from the email address associated with your account, or by writing to the postal address at the end of this Privacy policy. We will acknowledge your request within seven (7) calendar days and complete deletion within thirty (30) calendar days of verification, subject to the limited exceptions below.

Deletion timing and limited retention exceptions. When we receive a verified deletion request, we will deactivate your account and delete or anonymize your personal information from our active systems within thirty (30) calendar days, except where we are required or permitted to retain specific information to:

• complete outstanding orders, refunds, returns, payouts, and chargebacks;
• comply with tax, accounting, audit, anti-fraud, and other legal obligations (typically up to seven (7) years);
• resolve disputes, enforce our agreements with you or with third parties, and protect against fraud or abuse;
• retain aggregated or anonymized data that no longer identifies you.

Information held in routine system backups is deleted in the ordinary course of backup rotation as described in "How long do we keep your information?". After the applicable retention period, any remaining personal information is permanently deleted or anonymized.

Privacy-rights requests. For broader privacy-rights requests (access, portability, correction, restriction, objection, opt-out of sale or sharing), please contact us at dataprotection@suplery.com, privacy@suplery.com, or ccpa@suplery.com, as applicable. Verification and response timelines are described in the relevant sections above.