Supertab, Inc., is a wholly-owned subsidiary of Supertab AG,which provides through its website at www.supertab.co (the “Platform”), the Supertab service (the “Service”). We (Supertab, Inc.) are based at 450 Lexington Ave, 4th Floor, New York, NY, 10017. Supertab, Inc. is affiliated with Supertab GmbH, based in Neuturmstraße 5, 80331 Munich, Germany.

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This Privacy Policy applies to all visitors, end users, and others who access our Platform and Service either through our websites or via a third party who utilizes our Service.

Part I of this Privacy Policy informs you about the data processing if you are a consumer located within the U.S. or other parts of the world except the EU/EEA,UK and Japan.

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If you are a data subject located within the European Union (EU), the European Economic Area (EEA) or the United Kingdom (UK), please see part II of this Privacy Policy here.

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If you are a consumer located in Japan, pleasesee part III of this privacy policy.

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PART I – PRIVACY POLICY FOR CONSUMERS IN THE US AND OTHER PARTS OF THE WORLD EXCEPT THE EU/EEA/UK

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1.  OVERVIEW

This Privacy Policy explains how we, and some of the companies we work with,collect, use, share and protect information in relationto our Platform and Service and your choices about the collection and use of your information. Please read this Privacy Policy carefully. By using the Platform and/or Service, you agree to the collection and use of information in accordance with this Privacy Policy and our Terms of Service.

• By using the Supertab Platform and Service, you understand and agree that we are providing a platform that offers the ability for individuals or organizations to offer access management functions to individuals wishing to access digital content, products, or services on websites or applications. Furthermore, you understand and agree that in cases where access is granted in exchange for a payment, you may have the ability to “pay now” or to make a commitment to “pay later” by bundling multiple small transactions on to a single electronic ledger linked to you and/or your user device(s).
• Your agreement to the Terms of Service and this Privacy Policy is, of course, voluntary. Please understand, however, that you may not utilize our Service in any manner without agreeing to our Terms of Service and this Privacy Policy.

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2.  INFORMATION WE COLLECT

We collect the following types of information:

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1.  Information you may provide to us directly

• Your first and last name, password, e-mail, phone number and mailing address, a reference number that can be associated with your payment details, your payment history (if any) and login data, which you provide when you register for an account on the Service. When you sign up for our newsletter, we collect your name, e-mail, industry, and company. In addition to the information set forth above, we may collect information required by law, for instance in compliance with “know your customer” (KYC) procedures required to facilitate payments.
• Communications between you and the Service. For example, we may send you emails (e.g. account verification, changes/updates to features, technical and security notices). You may send us comments, questions, or requests.
• Additional details related to your use of the Service,including a record of your agreement to our Terms of Service, term of subscription and renewal periods, preferred billing method, user account details or credit card details or other terms of payment.

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 2.  Information you provide to us indirectly

Analytics information:

• The Service uses third party software analytics tools including, for example, but not limited to, tools provided by Google Analytics (a service provided by Google, Inc.) to help us measure traffic and usage trends on our website. The Service also uses Zendesk for customer support. These tools collect information sent by your device or by our Service to you, including the web pages you visit through our Service, add-ons, your anonymized IP address, and other information that assists us in gathering feedback to improve our products and our business model. We collect and use this analytics information together with analytics information from other users so that it cannot reasonably be used (and is not used) to identify any individual user. 

Cookies and similar technologies:

• When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Service and provide features to you. Cookies are small files that make it easier for you to use content from the providers that use our Service. Your Internet browser automatically receives these files from our servers and then saves the cookies on your computer. The Service use what are known as session cookies and persistent cookies. We send several persistent cookies to your computer. Among other things, cookies allow you to access Internet content across different websites. You can change the settings on your browser so that it informs you when it accepts a cookie, or so that it does not accept any cookies at all. We recommend that your browser be set to accept cookies from the Service, as only then will you be able to use the Service. We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

Log file information:

• Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
• When you use the Service, our servers automatically record certain log file information, including your web request, IP address, browsertype, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our users, which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

3.  HOW WE USE YOUR INFORMATION

 In addition to uses of information we describe elsewhere in this Privacy Policy, we use your data to do the following:

Enable the Service:

• We process your data, including your name, e-mail and mailing address, and payment information to process payments that you initiate when you use the Service. We further review a range of user data, including log files, IP addresses, mailing and e-mail addresses, and payment information in order to improve the Service, trouble-shoot and track issues with the Service, and identify areas for improvement.
• We use your personal data to communicate with you about the services we provide. For instance, for subscription service users, we use your contact information to notify you that your subscription will automatically be renewed soon or has expired. We also use user and payment data to handle support requests from users.
• In order to make sure our users of the Service receive payments, we engage in a payment settlement process. During this process, our payment service provider consults user data, including name, amounts owed and currency information and makes net payments to our users.

Perform credit, identity, and address checks:

• The success of our business depends on our preventing illegal or fraudulent transactions. To minimize our risks, among other processes, we compare usernames and country information against crime prevention watch lists upon registration.
• Analyze user behavior: We perform statistical and other analysis of your activities related to the Service, including your payments. We do this to gain a better understanding of how our Service is used so that we can provide you with a better, more intuitive and personalized experience and offer new products and services that may interest you.

Marketing:

• With your consent, we will use your data for marketing purposes, including to communicate with you about products, services, and other organizations and activities that may interest you. In order to tailor these communications, we evaluate your activities on the Service, often by using automated processing. In the course of using your data for marketing purposes, we will not forward it to third parties without your consent as explained in Section 6 below.

4.  HOW WE SHARE YOUR INFORMATION

We will not share your information with third parties outside of the Service or its Affiliates (defined below) except as noted in this Privacy Policy or with your explicit consent.

Parties with whom we may share your information:

• The Service may share limited information with Merchants and Distribution Partners (as defined in our Terms of Service) including your name, email address, phone number (if collected) and preferred language, as well as payment or payment commitment details, including the payment amount, the payment date, and similar, only after you have made a payment or a commitment to pay to that particular Merchant or Distribution Partner. Merchants or Distribution Partners may use this data to inform you by mail, email or digital advertising of their products and/or services that might be of interest, i.e. for marketing purposes. Merchants or Distribution Partners are not permitted to share your data with any third parties. Additionally, the Service may share the results of analysis of user behavior described above with other affiliates of the Service.

• We transmit certain user data to our payment service providers, e.g. credit card billing companies, banks, risk management provider and other financial institutions. We typically transmit the payment amount and a reference number that the payment service provider associates with your payment details. We also monitor whether payments from users are received on time and provide that information to Merchants and Distribution Partners. We share name, address, and country data with our payment service providers to help us perform some of the credit and fraud risk assessments described in Section 3.
• We may share certain information regarding Service content and/or your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of Supertab AG ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences).
• We also may share your information, including information from tools like cookies, log files, payment service providers, hosting providers, Google Analytics and other third-party organizations that help us connect you with the Service ("Third Party Service Providers"). Our Third Party Service Providers will be given access to your information as is reasonably necessary to provide Supertab with their services, under data processing agreements that require them, among other things, only to act on Supertab and instruction and to take sufficient technical and organizational measures to safeguard your data.
• We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

What happens in the event of a change of control:

• If we sell or otherwise transfer part or all of Supertab AG, its subsidiaries or affiliates, or its assets, to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), your information may be among the items sold or transferred. The buyer or transferee would be obligated to honor the commitments we have made in this Privacy Policy.

Responding to legal requests and preventing harm:

• We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that a law, regulation, or governmental request requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve, and share information when we have a good faith belief it is necessary to: detect, prevent, and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

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5.  HOW WE STORE YOUR INFORMATION

Storage and Processing:

• Your information collected through the Service may be stored and processed in the European Union and the United States, or any other country in which Supertab AG, its Affiliates or Service Providers maintain facilities.
• Supertab AG, its Affiliates, and/or Service Providers may transfer information that we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
• We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, Supertab AG cannot ensure the security of any information you transmit to the Service or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
• You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and the Service, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.

6.  YOUR CHOICES ABOUT YOUR INFORMATION

You are entitled to make choices about our handling of your data, from deleting or correcting data you include in your profile to opting out of advertising and other communication controls.

For personal data that we have about you:

• Delete Data: You can ask us to delete all or some of your personal data (e.g., if it is no longer necessary to provide the Service to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can ask us to update your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access Your Data: You can request a copy of your personal data. If you have any questions, you may contact us using the contact information below. We will only collect and process personal data about you where we have a lawful basis for doing so. Examples of lawful bases include consent (where you have given us consent for the processing, whether by agreeing to this Privacy Policy, ticking a box in a dialogue window, both, or by another explicit method), contract (where processing is necessary for us to perform our contract with you, for instance, to deliver the Service) and “legitimate interests.” Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. In those instances where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases on which we collect and use your personal data, please contact us as set forth below.

How long we keep your data:

• Retention. We will retain your information as long as your account is active, as necessary to provide you with our services or as otherwise set forth in this Privacy Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect our legal rights. We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our site, improve our services or comply with legal obligations.
• Your consent to the uses of your data outlined in this privacy policy are valid unless revoked.
• If you do not use our Service for a period of eighteen (18) months, we may delete your data for the Service. We may inform you, at our option, three (3) months before the expiration of this deadline and give you the opportunity to oppose this deletion.

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7.  CHILDREN'S PRIVACY

• The Service does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow minors to register for the Service. The Service and its content are not directed at anyone under the age of 18. In the event that we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 18, please contact us at privacy@supertab.co.

8.  OTHER WEB SITES AND SERVICES

• Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy or other terms do not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies.

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

• This Section applies only to users who are California residents, and to the Personal Information of such users that we collect. For California residents, Personal Information is defined by the CCPA (California Consumer Protection Act) as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

This California Notice does not address or apply to:

• Our handling of Personal Information that is exempt under Section 1798.45 of the CCPA;
• Personal Information we collect about individuals who are not California residents, or;
• Personal Information we collect about individuals acting in their capacity as representatives (“B2B contacts”) of users, to the extent we use their Personal Information only in the context of conducting our business relationship with the respective business.

The CCPA requires certain disclosures about the categories of Personal Information that we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it.

We do not sell your Personal Information.

California residents have the right to request: (1) that we disclose what Personal Information about them we collect, use, and disclose, including the specific pieces of the Personal Information about them collected by us in the preceding 12 months (known as a “request to know”); and (2) that we delete the Personal Information about them collected or maintained by us (known as a “request to delete”).

If you are a California resident and would like to submit a request to know or a request to delete, you may submit your request by e-mailing privacy@supertab.co.

Requests will be responded to, free of charge, within 45 days of receiving the request. Consistent with California law, you may only make two such requests in a 12-month period, and the information provided will only cover the information collected in the preceding 12 months.

In order to process a request, we will need to verify your identity. We may request two or more data points of Personal Information and other proof of identification depending on the nature of the request and the Personal Information requested to verify your identity.

As a California resident, you also have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us.

10.  HOW TO CONTACT US

If you have any thoughts or questions about this Privacy Policy, please contact us at privacy@supertab.co. If you live in the United States, the data controller responsible for your personal data is Supertab Inc.:

Supertab Inc.

Attn: Privacy Policy Inquiry 4th Floor 450 Lexington Ave

New York, NY, 10017

If you live outside the United States, please see part II of this Privacy Policy

Our EU representative is Supertab GmbH:

Supertab GmbH

Attn: Data Protection Officer Neuturmstrasse 5

80331 München GERMANY

11.  CHANGES TO OUR PRIVACY POLICY

Supertab Inc. may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

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PART II – PRIVACY POLICY FOR DATA SUBJECTS IN THE EU/EEA AND UK

This part of the Privacy Policy informs you as a data subject located in the EU/EEA or UK about the handling of your personal data by Supertab, Inc. and about your rights under the European General Data Protection Regulation (GDPR) and any national data protection laws, including the right to object to certain types of processing. See below for more information on your rights as a data subject. References to the European GDPR always implicitly include a reference to the corresponding regulation in the law of the United Kingdom, in which the European GDPR has been implemented into national law (UK GDPR).

I.  GENERAL INFORMATION

1.  Contact of the controller

Supertab, Inc., based at 450 Lexington Ave, 4th Floor, New York, NY, 10017 (hereinafter referred to as "we" or "us") is the controller of your data and is responsible for the data processing of individuals located in the EU/EEA and UK.

If you are located within the EU/EEA and have any questions or suggestions regarding this information, or if you would like to contact us about asserting your rights, please send your request to our EU representative:

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Supertab GmbH Neuturmstrasse 5

80331 Munich

Email help@supertab.co

The Data Protection Officer of Supertab GmbH can be contacted via dsb@supertab.co.

If you are located within the UK and have questions regarding this Privacy Policy, or if you would like to contact us about asserting your rights, please send your request to: help@supertab.co

If you are not located in the EU/EEA or UK or Japan, only part I of this Privacy Policy applies. If you are located in Japan, only part III of this Privacy Policy applies.

2.  Legal bases

The term "personal data" under data protection law refers to all information relating to an identified or identifiable individual. We process personal data in compliance with the relevant data protection regulations, in particular the GDPR. Data processing by us only takes place on the basis of a legal permission. We process personal data only with your consent (Art. 6 (1) (a) GDPR), for the performance of a contract to which you are a party or at your request for the performance of pre-contractual measures (Art. 6 (1) (b) GDPR), for the performance of a legal obligation (Art. 6 (1) (c) GDPR) or if the processing is necessary to protect our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms which require the protection of personal data override (Art. 6 (1) (f) GDPR).

3.  Duration of storage

Unless otherwise stated in this Privacy Policy, we store the data only for as long as is necessary to achieve the processing purpose or to fulfill our contractual or legal obligations. Such statutory retention obligations may arise in particular from commercial or tax law regulations. From the end of the calendar year in which the data was collected, we will retain such personal data contained in our accounting records for ten years and retain personal data contained in commercial letters and contracts for five to seven years (depending on the country you are located in). In addition, we will retain data in connection with consents requiring proof as well as with complaints and claims for the duration of the statutory limitation periods. We will delete data stored for advertising purposes if you object to processing for this purpose.

4.  Categories of data recipients

We use processors as part of the processing of your data. Processing operations carried out by such processors include, for example, hosting, sending e-mails, maintenance and support of IT systems, customer and order management, accounting and billing or marketing activities. A processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the data controller. Processors do not use the data for their own purposes but carry out data processing exclusively for the controller and are contractually obligated to ensure appropriate technical and organizational measures for data protection. In addition, we may transfer your personal data to bodies such as postal and delivery services, house bank, tax consultancy/auditing company or the financial administration. Further recipients are also set out below.

We are a globally active company with cross-border and cross-company teams. Data transfer to other companies in our group of companies can therefore not be ruled out.

5.  Data transfer to third countries

Our data processing operations may involve the transfer of certain personal data to third countries, i.e. countries that may not provide the same level of protection for your personal data (especially where the GDPR is not applicable law). Such a transfer takes place in a permissible manner if the European Commission or the UK government (as applicable) has determined that an adequate level of data protection is required in such a third country. Please find a list of the European Commission’s adequacy decisions here. Information regarding UK adequacy decisions can be found here.

If such an adequacy decision by the European Commission or the UK government (as applicable) does not exist, a transfer of personal data to a third country will only take place if appropriate safeguards exist pursuant to Art. 46 GDPR or if one of the conditions of Art. 49 GDPR is met.

Unless an adequacy decision is in place and otherwise specified below, we use:

(a)    the EU standard data protection clauses as appropriate safeguards for transfers of personal data to third countries outside of the EU; and

(b) the standard data protection clauses approved by the UK’s supervisory authority (the Information Commissioner’s Office) as appropriate safeguards for transfers of personal data to third countries outside of the UK.

You have the possibility to obtain a copy of these EU or UK standard data protection clauses or to inspect them. To do so, please contact us at the address given under Contact.

In exceptional circumstances, if there is no adequacy decision for a third country or appropriate safeguards in place with a recipient, if you consent to the transfer of personal data to third countries, the transfer will take place on the legal basis of Article 49 (1) (a) GDPR.

6.  Processing when exercising your rights

If you exercise your rights outlined in Your Rights below, we will process the personal data provided for the purpose of implementing these rights by us and to be able to provide evidence thereof. We will only process data stored for the purpose of providing information and preparing it for this purpose and for data protection control purposes and otherwise restrict processing in accordance with the GDPR.

These processing operations are based on the legal basis of Art. 6 (1) (c) GDPR (compliance with a legal obligation) in conjunction with your rights under the GDPR (Art. 15 to 22 GDPR).

7.  Your rights

As a data subject, you have the right to assert your data subject rights against us. In particular, you have the following rights:

●         In accordance with Art. 15 GDPR, you have the right to request information about whether and, if so, to what extent we are processing personal data relating to you or not and the right to access your personal data.

●         You have the right to demand that we correct your data in accordance with Art. 16 GDPR.

●         You have the right to demand that we delete your personal data in accordance with Art. 17 GDPR.

●         You have the right to have the processing of your personal data restricted in accordance with Art. 18 GDPR.

●         You have the right, in accordance with Art. 20 GDPR, to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format and to transfer this data to another controller.

●         If you have given us separate consent to data processing, you may revoke this consent at any time in accordance with Article 7 (3) GDPR. Such a revocation will not affect the lawfulness of the processing that was carried out on the basis of the consent until the revocation.

●         If you believe that a processing of personal data concerning you violates the provisions of the GDPR, you have the right to lodge a complaint with the relevant supervisory authority in accordance with Art. 77 GDPR. This means that you have the right to raise a complaint with the supervisory authority in the country where you live, work or where the infringement took place.

8.  Right of withdrawal

In accordance with Art. 21 GDPR, you have the right to object to processing in the following circumstances:

●         on grounds relating to your particular situation when the applicable legal basis is legitimate interests; In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data, which override your rights and freedoms. If this is the case, we will let you know; and

●         at any time when your personal data is processed for direct marketing purposes.

Where you receive marketing emails from us, you can unsubscribe by clicking on the unsubscribe link contained in each mailing or by sending an email to help@supertab.co.

II. DATA PROCESSING WHEN VISITING OUR WEBSITE

The following table describes what personal data is processed when you visit our Supertab website (https://supertab.co/).

When you visit our Supertab website, we collect information that you provide yourself. In addition, during your interaction with the website, we automatically collect certain information about your use of the website.

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III. DATA PROCESSING WHEN USING THE SUPERTAB SERVICE

Our Supertab service consists of

-          your user account (https://my.supertab.co/), where you can view and manage all purchases and payments, and

-          the user interface, which is integrated with our partners and through which you can directly purchase the content of our partners.

The following table describes what personal data is processed when you use our Supertab service.

When you use our Supertab service, we collect information that you provide yourself. In addition, during your interaction with the service, we automatically collect certain information about your use of the service.

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IV. FURTHER DATA PROCESSING

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PART III – PRIVACY POLICY FOR PERSONS IN JAPAN

1.  OVERVIEW

This Privacy Policy explains to you as a person in Japan how we, and some of the companies we work with, collect, use, share and protect information in relation to our Platform and Service and your choices about the collection and use of your information. Please read this Privacy Policy carefully. By using the Platform and/or Service, you agree to the collection and use of information in accordance with this Privacy Policy and our Terms of Service.

●         By using the Supertab Platform and Service, you understand and agree that we are providing a platform that offers the ability for individuals or organizations to offer access management functions to individuals wishing to access digital content, products, or services on websites or applications. Furthermore, you understand and agree that in cases where access is granted in exchange for a payment, you may have the ability to “pay now” or to make a commitment to “pay later” by bundling multiple small transactions on to a single electronic ledger linked to you and/or your user device(s).

●         Your agreement to the Terms of Service and this Privacy Policy is, of course, voluntary. Please understand, however, that you may not utilize our Service in any manner without agreeing to our Terms of Service and this Privacy Policy.

2.  INFORMATION WE COLLECT

We collect the following types of information:

1.  Information you may provide to us directly

●         Your first and last name, password, e-mail, phone number and mailing address, a reference number that can be associated with your payment details, your payment history (if any) and login data, which you provide when you register for an account on the Service. When you sign up for our newsletter, we collect your name, e-mail, industry, and company. In addition to the information set forth above, we may collect information required by law, for instance in compliance with “know your customer” (KYC) procedures required to facilitate payments

●         Communications between you and the Service. For example, we may send you emails (e.g. account verification, changes/updates to features, technical and security notices). You may send us comments, questions, or requests.

●         Additional details related to your use of the Service, including a record of your agreement to our Terms of Service, term of subscription and renewal periods, preferred billing method, user account details or credit card details or other terms of payment.

2.  Information you provide to us indirectly

Analytics information:

●         The Service uses third party software analytics tools including, for example, but not limited to, tools provided by Google Analytics (a service provided by Google, Inc., https://marketingplatform.google.com/about/analytics/) to help us measure traffic and usage trends on our website. The Service also uses Zendesk (https://www.zendesk.com/about/) for customer support. These tools collect information sent by your device or by our Service to you, including the web pages you visit through our Service, add-ons, location data, your anonymized IP address, and other information that assists us in gathering feedback to improve our products and our business model. We collect and use this analytics information together with analytics information from other users so that it cannot reasonably be used (and is not used) to identify any individual user.

Cookies and similar technologies:

●         When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Service and provide features to you. Cookies are small files that make it easier for you to use content from the providers that use our Service. Your

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Internet browser automatically receives these files from our servers and then saves the cookies on your computer. The Service uses what are known as session cookies and persistent cookies. We send several persistent cookies to your computer. Among other things, cookies allow you to access Internet content across different websites. You can change the settings on your browser so that it informs you when it accepts a cookie, or so that it does not accept any cookies at all. We recommend that your browser be set to accept cookies from the Service, as only then will you be able to use the Service. We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

Log file information:

●         Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.

●         When you use the Service, our servers automatically record certain log file information, including your web request, IP address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our users, which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

3.  HOW WE USE YOUR INFORMATION (PURPOSE)

In addition to uses of information we describe elsewhere in this Privacy Policy, we use your data to do the following:

Enable the Service:

●         We process your data, including your name, e-mail and mailing address, and payment information to process payments that you initiate when you use the Service. We further review a range of user data, including log files, IP addresses, mailing and e-mail addresses, and payment information in order to improve the Service, trouble-shoot and track issues with the Service, and identify areas for improvement.

●         We use your personal data to communicate with you about the services we provide. For instance, for subscription service users, we use your contact information to notify you that your subscription will automatically be renewed soon or has expired. We also use user and payment data to handle support requests from users.

●         In order to make sure our users of the Service receive payments, we engage in a payment settlement process. During this process, our payment service provider consults user data, including name, amounts owed and currency information and makes net payments to our users.

Perform credit, identity, and address checks:

●         The success of our business depends on our preventing illegal or fraudulent transactions. To minimize our risks, among other processes, we compare usernames and country information against crime prevention watch lists upon registration.

●         Analyze user behavior: We perform statistical and other analysis of your activities related to the Service, including your payments. We do this to gain a better understanding of how our Service is used so that we can provide you with a better, more intuitive and personalized experience and offer new products and services that may interest you.

Marketing:

●         With your consent, we will use your data for marketing purposes, including to communicate with you about products, services, and other organizations and activities that may interest you. In order to tailor these communications, we evaluate your activities on the Service, often by using automated processing. In the course of using your data for marketing purposes, we will not forward it to third parties without your consent as explained in Section 6 below.

4.  HOW WE SHARE YOUR INFORMATION

We will not share your information with third parties outside of Supertab or its Affiliates (defined below) except as noted in this Privacy Policy or with your explicit prior consent.

Parties with whom we may share your information:

●         We may share limited information with Merchants and Distribution Partners (as defined in our Terms of Service) including your name, email address, phone number (if collected) and preferred language, as well as payment or payment commitment details, including the payment amount, the payment date, and similar, only after you have made a payment or a commitment to pay to that particular Merchant or Distribution Partner. Merchants or Distribution Partners may use this data to inform you by mail, email or digital advertising of their products and/or services that might be of interest, i.e. for marketing purposes. Merchants or Distribution Partners are not permitted to share your data with any third parties. Additionally, we may share the results of analysis of user behavior described above with other affiliates of the Service.

●         We transmit certain user data to our payment service providers, e.g. credit card billing companies, banks, risk management provider and other financial institutions. We typically transmit the payment amount and a reference number that the payment service provider associates with your payment details. We also monitor whether payments from users are received on time and provide that information to Merchants and Distribution Partners. We share name, address, and country data with our payment service providers to help us perform some of the credit and fraud risk assessments described in Section 3.

●         We may share certain information regarding Service content and/or your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of Supertab AG ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences).

●         We also may share your information, including information from tools like cookies, log files, payment service providers, hosting providers, Google Analytics and other third-party organizations that help us connect you with the Service ("Third Party Service Providers"). Our Third Party Service Providers will be given access to your information as is reasonably necessary to provide Supertab with their services, under data processing agreements that require them, among other things, only to act on Supertab and instruction and to take sufficient technical and organizational measures to safeguard your data.

●         We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

●         Other cases permitted by the Act on the Protection of Personal Information (Act No. 57 of 2003) or by other laws or regulations

●         The recipients include third parties in countries or regions outside of Japan. The countries or regions where these entities are located are as follows (please refer to “PART II – PRIVACY POLICY FOR DATA SUBJECTS IN THE EU/EEA AND UK” above for details of the information to be provided):

(1)  Third Parties located in the United States of America

Please refer to the following link for more information on the protection of personal information in the United States of America: https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/

Personal information protection measures to be taken by the third parties:

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(2)  Third Parties located in the United Kingdom or in Member States of the European Union Supertab AG (Germany)

Supertab GmbH (Germany) Google Ireland Limited (Ireland)

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Amazon Web Services EMEA SARL (Luxembourg) Personio, Personio SE & Co. KG (Germany) CookieYes Limited (United Kingdom) Salesforce.com Germany GmbH (Germany)

What happens in the event of a change of control:

●         If we sell or otherwise transfer part or all of Supertab AG, its subsidiaries or affiliates, or its assets, to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), your information may be among the items sold or transferred. The buyer or transferee would be obligated to honor the commitments we have made in this Privacy Policy.

Responding to legal requests and preventing harm:

●         We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that a law, regulation, or governmental request requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve, and share information when we have a good faith belief it is necessary to: detect, prevent, and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

How we record the provision of information to or by third parties:

●         When we provide personal information to a third party, we will create a record of such provision and store these records. When we receive personal information from a third party, we perform the necessary confirmation, and we create a record of such confirmation and store these records.

5.  HOW WE STORE YOUR INFORMATION

Storage and Processing:

●         Your information collected through the Service may be stored and processed in the European Union and the United States, or any other country in which Supertab AG, its Affiliates or Service Providers maintain facilities.

●         Supertab AG, its Affiliates, and/or Service Providers may transfer information that we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

●         We take necessary and appropriate measures to safely manage and to prevent leakage, loss, or damage of user information. If we outsource the handling of personal information to a third party, we will confirm the handling of personal information by the third party by measures such as concluding an outsourcing contract and receiving periodic reports, etc.. For specific details of our security control measures, please contact us as described in Chapter 10 of this Part III of the Privacy Policy.

●         We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, Supertab AG cannot ensure the security of any information you transmit to the Service or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

●         You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and the Service, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.

6.  YOUR CHOICES ABOUT YOUR INFORMATION

You are entitled to make choices about our handling of your data, from deleting or correcting data you include in your profile to opting out of advertising and other communication controls.

When we receive a request from a user according to the Act on the Protection of Personal Information on any personal data retained, such as a request for disclosure, correction and utilization cease, etc. we will

appropriately and without delay meet such request pursuant to applicable laws and regulations. For specific information on how to make such request, please contact us as described in Chapter 10 of this Part III of the Privacy Policy.

How long we keep your data:

●         Retention. We will retain your information as long as your account is active, as necessary to provide you with our services or as otherwise set forth in this Privacy Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect our legal rights. We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our site, improve our services or comply with legal obligations.

●         Your consent to the uses of your data outlined in this privacy policy are valid unless revoked.

●         If you do not use our Service for a period of eighteen (18) months, we may delete your data for the Service. We may inform you, at our option, three (3) months before the expiration of this deadline and give you the opportunity to oppose this deletion.

7.  CHILDREN'S PRIVACY

●         The Service does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow minors to register for the Service. The Service and its content are not directed at anyone under the age of 18. In the event that we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 18, please contact us at privacy@supertab.co.

8.  OTHER WEB SITES AND SERVICES

●         Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy or other terms do not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies.

10.  HOW TO CONTACT US

 Please direct any comments, questions, complaints, or other inquiries regarding the handling of your information to the following contact point:

Supertab, Inc.

Privacy Policy Inquiry 4th Floor Data protection officer: Eric Larsen 450 Lexington Ave

New York, NY, 10017

E-mail privacy@supertab.co

11.  CHANGES TO OUR PRIVACY POLICY

Supertab Inc. may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

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