Privacy Policy

Welcome to Superflow, the creator platform for active learning. Superflow, Inc., a Delaware corporation, along with our subsidiaries and affiliates (“Superflow”, “we”, “us,” or “our”),respect your privacy and we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use, and share it.

About this Policy

This Privacy Policy (“Privacy Policy”) details our data collection processes, including the data we receive about you and how we process it, and your rights and obligations in relation to your personal data.

Unless we link to a different policy or state otherwise, thisPrivacy Policy applies when you visit or use the Superflow services such as anySuperflow website (the “Site”), community and customer service links or chat functionality, mobile applications, social media pages or handles, online and offline products and events, APIs or related services, and any accompanying services you are eligible to receive, such as Creator support services and tools (together, the “Services”). It also applies to prospective customers and enterprise products. By using or accessing the Services, you agree to the terms of this Privacy Policy. From time to time, we may develop new or offer additional services. They'll also be subject to this Privacy Policy, unless stated otherwise when we introduce them.

Capitalized terms not defined here have the meanings set forth in the Terms of Service (the “Terms”), located at www.superflow.team/terms. Your use of the Sites and Services is also subject to the Terms. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services, including the Governing Documents.

Personal Data We Collect About You

When you register with us, when you become a Superflow Member, when you choose to create or participate in a Flow, we may ask you for Personal Data. “Personal Data” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, customer or household. In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data. This is not PersonalData. To the extent this data is stored or associated with Personal Data, it will be treated as Personal Data; otherwise, the data is not subject to this Privacy Policy.

These tables set out the categories of personal data we collect and use.

Information you provide to us when you sign up for the Services, update your account, or use the Services

User  Data & Identifiers

Personal data that we need to create your  account and that enables you to use the Services.

The  specific types of information we collect will depend upon the Services you  use, how you use them, and the information you choose to provide. The types  of data we collect directly from you includes name, alias, email address or  other similar identifiers.

Payment  Information

If you sign up for a paid membership, creator pro or enter license, or  other service, or make purchases, we collect certain data about your purchase  (such as your name, billing address, and ZIP code) as necessary to process  your order and which may be saved to process future orders. The exact  personal data collected and used will vary depending on the payment method.

You  must provide certain payment and billing data directly to our payment service  providers, including your name, credit card information, billing address, and  ZIP code. We may also receive limited information, like the fact that you  have a new credit card and the last four digits of that card, from payment service  providers to facilitate payments. Superflow does not collect or store sensitive  cardholder data, such as full credit card numbers or card authentication  data.

Creator  Payment Information

If you are a Superflow Creator, you can  provide your payment account to the Services to receive payments through our  third party service providers. When you link a payment account, we collect  and use certain information, including your payment account email address,  account ID, physical address, or other data necessary for us to send payments  to your account. In some instances, we may collect ACH or wire information to  send payments to your account. In order to comply with applicable laws, we  also work with trusted third parties who collect tax information as legally  required. This tax information may include residency information, tax  identification numbers, biographical information, and other personal  information necessary for taxation purposes.

Other  Information

Additional data you may choose to give us  includes:

·        demographic information such as your gender  or other information;

·        user-generated content you provide to us,  such as when you upload a project, upload content, leave a Flow review, ask  or answer a question, or otherwise participate in a public discussion forum;

·        information you provide when you participate  in a survey or research study, including testimonials;

·        participation in promotions, sweepstakes or  contests, or other marketing promotions;

·        Information you provide when you  communicate with our customer support team; and

·        Information about others, including email  address, for referral invitations.


Information automatically collected through   your use of the Services

Usage  Data

When you use our Services, we collect and  analyze:

·        technical data such as your IP address,  browser types, browser language, operating system, software and hardware  attributes (including device IDs), online identifiers such as cookie data,  referring and exit pages, and URLs;

·        site usage patterns such as the number of  clicks, mouse movements, scrolling, and time spent on a page;

·        navigation data such as pages viewed and  the order of those pages, date and time of use, session duration, and error  logs;

·        learning data such as content or Flows completed, total activites done and

·        other similar information.

We may  use third-party providers such as Amplitude  and Fullstory to log your activity. This provides us with a set of data and  a session replay of your activity on Superflow in the form of a video.  Third-party providers like Amplitude  and Fullstory capture  and analyze your usage data to help us make your Superflow experience better.

General  (Non-Precise) Location

Your general location includes country,  region, or state. We may learn this from technical data (e.g. your IP  address, language setting of your device) or payment currency.


Information collected   from partners and other third parties

Third Party Services

If you link, connect, or login  to the Services with a third party service (e.g. Google, Apple), you direct  the service to send us information such as your registration and profile  information as controlled by that service or as authorized by you via your  privacy settings at that service.

Payment Partners and Merchants

If you choose to pay through  third parties or by invoice, we may get data from our payment partners. This  allows us to send you invoices or process your payments.

If we direct you to a merchant, we receive data from the  merchant that is related to your purchase. For example, we might direct you  to one of our partner’s websites on a third party platform. Receiving this  data allows us to analyze the effectiveness of our partnership with these  merchant partners and understand your interests.

 

How We Use the Personal Data We Collect About You

 

We may use the information we collect about you to provide, analyze, administer, enhance, and personalize the Services; to process your subscription, purchase, or payments; to communicate with you on these and other topics; to evaluate and improve the Services; and to comply with legal obligations. For example, we use such information to:

·      create and manage your accounts and profiles;

·      personalize your content on the Services–this includes providing you access to your saved Flows and Flow watch history, and providing Flow recommendations;

·      provide creators and users with features and functionality, including to facilitate participation in our content, Flows, sessions, and live events, and that of our creators; issue completion certificates, or other credentials; or to facilitate social or community features among the users who has access to a Flow determined by the Flow creator in the privacy settings, such as by identifying and suggesting connections with other users or creators of the Service and providing discussion boards, chat, or messaging functionality;

·      provide creatorswith information related to userengagement and activities done,referral earnings, and other analytical data, including data that is used topay creators appropriately;

·      manage User and Creator referrals;

·      secure our systems, prevent fraud, and help us protect thesecurity of Superflow accounts; prevent,detect, and investigate potentially prohibited or illegal activities, includingfraud, and to enforce our Termsof Service;

·      fulfill contractual obligations with third parties;

·      complete corporate transactions (for more information, see our“Business Transfers” section below); and

·      fulfill any other purpose at your direction.

 

Disclosing Your Personal Data

 

Affiliates and Subsidiaries

To support us in providing, integrating, promoting, and improving the Services, we may share personal information within our corporate family of companies that are related by common ownership or control.

With Your Consent or at Your Direction

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Superflow account or participating in promotional activities by Superflow partners or third parties.

Educational Experience

To facilitate interactions between our Creators and users, we share with Creators data that we have about users concerning content users access, started, completed or request information about, so Creators can improve their content for you and other Users.

Depending on your settings, your created Flows, shared content and profile data may be publicly viewable, including to other Users and Creators. If you leave are view, ask a question, or post on a discussion board, your information(including your name) may also be publicly viewable depending ont he publicity of the workspace or Flow you leave your comment or review about. Note that within the Services, all discussion boards, groups, or other public forums available to participants are also visible to the same participant group. Accordingly, please take care when using these forums and do not post confidential or proprietary information through those features.

Service Providers

We share Personal Data with vendors, service providers, and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

·      Payment processors

·      Fraud prevention service providers

·      Analytics service providers

·      Engineering and development tools

·      Staff augmentation and contract personnel

·      Hosting service providers

·      Creators

Aggregate/AnonymousData

From time to time, we may share aggregated or anonymous information about use of the Services, such as by publishing a report on usage trends.

Protection of Superflow and others

We also share Personal Data when we believe it is necessary to:

·      Comply with applicable law or respond to valid legal process,including from law enforcement or other government agencies;

·      Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud;

·      Maintain the security of our products and services.

LegalBases for Use of Your Information

We process Personal Data for, or based on, one or more of thefollowing legal bases:

Performanceof a Contract

By using the Services, you have contracted with us through theTerms of Service, and we will process certain Personal Data to perform under that contract, including first and last name, email address, password, and, if you are a Creator, the content of your Flows. When we process Personal Data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

LegitimateInterests

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: first and last name, email address, location information, IP address, and your activity on the Services, including Flow usage information and community interaction data. Examples of these legitimate interests include: operation and improvement of our business, products, and services; analyzing the use of the Services; provision of customer support; protection from fraud or security threats; compliance with legal obligations; and completion of corporate transactions.

Consent

In some cases, we process Personal Data based on the consent youexpressly grant to us prior to the time we collect such data. When we processPersonal Data based on your consent, it will be expressly indicated to you prior to the point and time of collection.

Other Processing Grounds

From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Retention of Your Information

We will retain your Personal Data for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will also retain and use yourPersonal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Protectionof Your Information

Superflow takes technical and organizational security measures that are designed to safeguard Personal Data. Please recognize that protecting your Personal Data is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the Contact Us section of our website.

Use of Cookies and Other Tracking Technologies

We and our service providers use cookies, web beacons, pixels, session replay/screen capture, and similar technologies to collect information and personalize your experience with our Services.

We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i)recognize your computer; (ii) store your preferences and settings; (iii)understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.

As we adopt additionaltechnologies, we may also gather information through other methods. Please notethat you can change your settings to notify you when a cookie is being set orupdated or to block cookies altogether. For more information, please consultthe “Help” section of your browser (e.g., Internet Explorer; Google Chrome;Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, ormanaging any or all cookies, you may not have access to certain features orofferings of the Services.

 

Children’sInformation

The Services are not directed to children whose age:

·      is under the age of 16 years;

·      makes it illegal to process their personal data; or

·      requires parental consent to process their personal data.

We do not knowingly process data of children under the age of 16 without parental consent. If we become aware that we have collected data from a child under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. If you are under the age of 16 years, please do not use the Services, and do not provide any personal data to us without parental consent.

We also comply with other age restrictions and requirements in accordance with applicable local laws.

If you're a parent of a child under the age of 16, as applicable, and become aware that your child has provided personal data to Superflow, please Contact Us. If we learn that we've collected the personal data of a child under the age of 16, as applicable, we'll take reasonable steps to delete the personal data. This may require us to delete the Superflow account associated with that personal data.

Your Rights

You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this PrivacyPolicy, or by following instructions provided in this Privacy Policy or in communications sent to you.

Your rights vary depending on the laws that apply to you, butmay include:

·      The right to know whether, and for what purposes, we processyour Personal Data;

·      The right to be informed about the Personal Data we collectand/or process about you;

·      The right to learn the source of Personal Data about you weprocess;

·      The right to access, modify, correct, and delete Personal Dataabout you (see the “Accessing, Modifying, and Correcting Collected PersonalData” section below for more information);

·      The right to know with whom we have shared your Personal Data,for what purposes, and what Personal Data has been shared (including whetherPersonal Data was disclosed to third parties for their own direct marketingpurposes);

·      The right to withdraw your consent, where processing of PersonalData is based on your consent; and

·      The right to file a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

 We may reject requests that are unreasonable or not required bylaw, including those that would be extremely impractical, could required is proportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes, and to fulfil the purposes described in thisPrivacy Policy. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

We currently do not collect household data. If all the members of a household make a request under this Policy, we will respond as if the requests are individual requests.

Please note, if you do not have a Superflow account and you use Superflow as a guest user, we will not have enough information about you to verify your requests under thisPolicy, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to Superflow where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per12-month period.

Accessing,Modifying, and Correcting Collected Personal Data

We strive to maintain the accuracy of any Personal Data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. You can request that we correct or supplement such data by emailing support@superflow.team.

Depending on the laws that apply to you, you may obtain from us certain Personal Data in our records. If you wish to access, review, or make any changes to Personal Data you have provided to us through the Services, please email us at support@superflow.team from the email address that you believe is associated with your Superflow account.

Data Erasure

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

·      We may retain your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Superflow account for fraud or safety reasons, we may retain information from that account to prevent that member from opening a new account in the future.

·      We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep information for tax, legal reporting, and auditing obligations.

·      Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.

·      Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

 

Changes to Our Privacy Policy

This Privacy Policy replaces all previous disclosures we may have provided to you about our information practices with respect to theServices. Our Services may change from time to time. As such, we reserve the right, at any time, to modify, alter, and/or update this Privacy Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Policy. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Policy, such as by posting a notice on the Services or sending you an email. The date this Privacy Policy was last updated is identified at the top of the page. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your agreement of the amendedPrivacy Policy.

Contact Us

If you have any questions about this Privacy Policy or our datapractices generally, please contact us using the following information:

Name:

Superflow, Inc.

Email address for contact:

support@superflow.team 

Mailing address:

16192 Coastal Highway,Lewes, Delaware, 19958, County of Sussex

Designated EU & UK representative mailing address:

Superflow Learning Technologies Kft, 1022 Budapest, Kapor u4. 1/6.

Please contact support@superflow.team  if you need to access this Privacy Policy in an alternative format due to having a disability.

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