PRIVACY POLICY
Super3io.com
Effective from June 13, 2020
This website is created, owned, and operated by Super3io (or the "Trainer"), a Singapore-registered limited liability company; using a template and ongoing back-end support provided by Wix.com, Inc. (the “Developer”). We work diligently to protect the privacy, confidentiality, and security of the Personal Information (defined below) that we receive. This Privacy Policy describes the principles and practices that apply to the Personal Information that we collect from individuals online or offline (the “User,” or “you”); such as individuals who browse through Super3io’s “Site” (www.Super3io.com); register on the Site; use the services provided on the Site; interact with the Site; communicate with Super3io through telephone, email, text, or other communications means; participate in Super3io's interviews, surveys, or promotions; read or receive Super3io's articles; or apply for employment with Super3io.
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Privacy Principles
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This Privacy Policy is based on the following privacy principles:
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Accountability—Super3io will not disclose your Personal Information to third parties other than as described in this Privacy Policy or Super3io’s written agreements with you, and Super3io’s agreements with third parties with whom Super3io share Personal Information will reflect our privacy principles.
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Limited by Purpose—Super3io collect Personal Information only for specific, explicit, and legitimate purposes, and refrain from further processing that Personal Information in any manner that is incompatible with those purposes (subject to our reasonable archive, backup, and research practices).
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Data Minimization—Super3io process only that Personal Information which is adequate, relevant, and necessary to achieve the purposes for which it is collected.
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Storage Limitation—Super3io keep data in personally-identifiable form only for as long as necessary to achieve the purposes for which it is being processed (subject to our reasonable archive, backup, and research practices).
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Options—Super3io will provide you with mechanisms that will allow you to opt out of (i) our direct marketing campaigns; (ii) the disclosure of your Personal Information to third parties who are not acting as our agents; and (iii) the use of your Personal Information for purposes that are materially different from the purpose for which Super3io originally collected the Personal Information.
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Integrity, Confidentiality, and Security—Super3io take reasonable measures to protect the security of your Personal Information, and Super3io’s agreements with third parties with whom Super3io share Personal Information require similar protections. The Developer has implemented security measures designed to protect the Personal Information you share, including physical, electronic and procedural measures. Among other things, the Developer offers HTTPS secure access to most areas on their services; the transmission of sensitive payment information (such as a credit card number) through their designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and they regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. The Developer also regularly monitor their systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of the Site.
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Regardless of the measures and efforts taken by the Developer, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Information or any other User Content you upload, publish or otherwise share with the Developer or anyone else.
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Lawfulness, Fairness, and Transparency—Super3io will process your Personal Information only when we have a legal basis for doing so, and Super3io will process your Personal Information in a manner that is fair and transparent to you.
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Non-Discrimination—Super3io will not discriminate against you if you choose to exercise your privacy rights.
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Notice—Super3io will not collect or transfer your Personal Information without your knowledge. Super3io inform you of such collection and transfer through this Privacy Policy, Super3io’s written agreements with you, and other disclosures Super3io make available on the Site.
Definitions
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In this Privacy Policy, the following terms are defined as set forth in this section:
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“Assessment” means an instrument, questionnaire, or series of tests that are completed by one or more Respondents to provide information about a Respondent to the Respondent, to the Trainer, and the Trainer’s Customers.
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“Certified Practitioner” means an individual who has successfully completed (i) one or more of Super3io’s certification programs for certain Assessments, (ii) one or more Assessments to one or more Respondents and (iii) who interprets the Reports (or other output generated by the Trainer) to provide feedback to the Respondent(s) about the Reports.
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“Child” or “Children” means those individuals who are (i) in the United States and under age 13; (ii) in the European Union and under age 16; or (iii) in other countries or territories and under the minimum age of threshold to be considered an adult.
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“Customer” means an individual, business, or other entity that purchases the Trainer’s Products or Services, or with which the Trainer has a contractual relationship to provide Products or Services.
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“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. Personal Information includes, for example, name, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Products or Services or which you may choose to provide to the Trainer. It also includes other information, such as IP address, device information, or other Session Data (as defined below) that can reasonably be linked to a specific individual, computer, or other device.
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“Practitioner” means an individual who administers one or more Assessments to one or more Respondents and who interprets the Reports (or other output generated by the Trainer) to provide feedback for the Respondent(s).
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“Products or Services” means the products or services promoted, sold, available for sale or available for use on the Site; such as books, Assessments, Reports, and other supplemental materials.
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“Reports” means an analysis of the scoring and responses provided in connection with an Assessment, which a Practitioner or Customer may use to interpret a Respondent’s responses to an Assessment. Some Reports, such as those generated on the Site, do not require an interpretation from a Practitioner.
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“Respondent” means an individual who takes, will take, or has taken an Assessment.
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“Session Data” means, as applicable, usage information, such as IP address, unique identifier of an individual’s mobile device, the type of browser, type of operating system, referring URL, date, time and duration of a visitor’s visit, the number of visits to a Site, the pages viewed, order of pages viewed, time spent on a particular page, the number of cookies accumulated, bytes sent, bytes received, protocol version, user agent, method, URI stem, URI query, or MAC address.
Your Agreement to this Privacy Policy
By creating an account, using the Site, and/or submitting Personal Information to Super3io, you agree to the practices described in this Privacy Policy, and you agree that we may collect, use, disclose, store, transmit, and/or process such Personal Information in accordance with this Privacy Policy or as required by law.
If you reside in a country or territory that restricts the transfer of Personal Information out of that country or territory, you agree to the transfer, storage, and processing of your Personal Information to countries that may not have data protection laws which provide the same level of protection as those that exist in your country of residence.
Children are not permitted to use the Site. Should we discover that a Child has sent Personal Information directly to us, we will use that information only to respond directly to that Child to inform him/her that we will not continue to process his/her Personal Information.
Links to External Sites
The Sites may link to websites that are operated by third parties. Because such websites are not operated by Super3io, they are not subject to this Privacy Policy. Super3io recommend that you read the privacy statements that are posted on these third-party websites to understand their procedures for collecting, using, and disclosing Personal Information.
What Personal Information We Collect and How
We collect only such Personal Information as necessary to (i) provide our Products or Services to you; (ii) inform you about our Products and Services; (iii) continue our research in the field; and (iv) improve our Site, Products or Services, and your experience interacting with Super3io. We describe below the different ways in which WP collect or obtain Personal Information. Unless otherwise stated below, the legal basis for Super3io’s processing of your Personal Information is Super3io’s legitimate business interest in (i) providing the Site, Products, or Services to you; or (ii) contacting or considering you as a candidate for employment with Super3io.
While the Trainer may disclose your Personal Information for the business purposes set forth below, the Trainer does not sell your Personal Information to third parties.
Site Visits—When you visit the Site, Super3io automatically collect the related Session Data. Session Data is provided to Super3io by your browser, by third-party integrations on the Site, and through log files, which record your activities while browsing the Site, such as when you click on a link. Super3io may record some of these data in one or more cookies that the Site send to your browser.
Account Creation and Registration—If you register or create an account, Super3io require that you provide certain Personal Information during account registration. Super3io collect your name, email address, contact information, and other information, and may ask you for other optional information that helps Super3io serve you better.
Completion of Assessment—If you complete an Assessment, Super3io collect your name, email address, contact information, Assessment responses, Session Data, and other information you may choose to provide or associate with your account. In some cases, Super3io ask questions to which the response is optional (such as demographic questions), and these questions are identified as such. In some instances, these optional demographic questions may involve collection of special categories of Personal Information, such as information regarding your racial or ethnic origin. You are free not to respond to these optional questions. All such optional questions require your explicit, informed consent.
Participation in Surveys—If you choose to participate in Super3io’s surveys, Super3io may collect Personal Information such as your name, email address, and any other Personal Information that you may provide in your survey responses. Participation in surveys is optional, and Super3io give you the means to opt out of being contacted for surveys.
Receiving Marketing Information—If you sign up to receive Super3io’s marketing communications, Super3io may collect information on the open rate of the communications, and whether a specific individual has clicked on a link contained in a particular communication. Super3io’s marketing communications contain instructions on how to opt out of receiving future marketing communications if you no longer wish to receive them.
Association with Super3io’s Customer or client—If you are a Customer or client or prospective Customer or Client, or if you are an employee or associate of a Customer or client, Super3io may collect your name, email address, telephone number, and other contact information in the regular course of Super3io’s interaction with you.
Interaction with third parties regarding our Products or Services—Super3io may receive Personal Information about you from third parties, such as from Customers, media where we advertise, business partners, and service providers. Some of these information pertains to a specific individual; other information can only be linked to an access point or a device.
Application for employment—If you choose to apply for an open position of employment, we may collect Personal Information such as your name, email address, and any other Personal Information that you may provide in conjunction with your application. Super3io use this information only to consider you as a candidate for the position for which you are applying and to contact you for legitimate purposes relating to that application.
Participation in our training programs—Super3io may use Session Data to monitor and limit the registration and attendance of participants in the program.
How We Use Personal Information
Super3io use Personal Information in order to provide and enhance the Products or Services that the Trainer offers as follows:
To improve the experience of the Site—Super3io use Session Data to ease navigation throughout the Site, to enhance navigation, keep track of login name and password in order to avoid requesting identity information when the visitor moves from page to page, and in general to enhance the quality of the Site and the content provided on the Site.
For Assessment and Team-Building Purposes—Super3io use the responses to Assessments to score the Assessments and to generate Reports and other data related to the Respondents to those Assessments. Super3io sometimes combine data from multiple Respondents (for example, in team reports). Super3io may also combine Respondent data with our general research data, or compare or associate Respondent data with other Respondent data. Certain subsets of these data are made available to our Customers, but your Personal Information is only shared with a Customer if you complete an Assessment that has been sponsored by that Customer.
To validate certification status—If you are or become a Certified Practitioner, Super3io may share information regarding your certification, such as your name, the instruments in which you are certified/qualified, the date(s) of your certification/qualification, and the current status of your certification/qualification with individuals who inquire about such information.
For research purposes—Super3io may use aggregated Session Data to better understand how the Site is navigated, how many visitors arrive at specific pages, which pages or content attract more viewers, the length and frequency of stays at the Site, the different types of searches of the Site’s content and databases, the types of browsers and computer operating systems that Site visitors use, and the IP addresses from which visitors connect to our Site, in order to improve the Site and enhance Super3io’s content. Super3io may use IP addresses to gather broad demographic information—information that is not associated with any individual, and is therefore anonymous. Super3io also use aggregated Assessment responses, demographic data, and other data to improve our Products and Services. Super3io may use location information gathered for research and development purposes.
For maintenance purposes—Super3io may use IP addresses and Session Data to diagnose problems with Site server, and to administer our Site.
For marketing purposes—Super3io may use email addresses or other contact information to send mailings, newsletters, and other marketing communications regarding product information and releases. Super3io may use your telephone number to contact you for marketing purposes. Super3io may use pixel tags to monitor the open rate of our communications. This helps Super3io understand the effectiveness of the communications that are sent. Super3io provides you with the option to opt out of marketing communications at any time.
For survey analysis—The information that Super3io collect through our surveys is not used other than to garner survey results and statistical analysis. Super3io will not sell these information.
To Whom Super3io Disclose Personal Information
From time to time, Super3io may disclose Personal Information to someone other than the individual who provided the Personal Information, as further described below:
Customers—The Trainer provides its Customers with the information that they need to properly administer or interpret Assessments. If you take an Assessment at the direction of one of our Customers, that Customer will receive from the Trainer one or more Reports based on the Assessment you took and the responses you provided to that Assessment so that the Customer may properly counsel or advise you or provide you with other services.
Gift Recipients—If you purchase Products or Services for use by another individual (for example, as a gift), then Super3io may provide the recipient of such Products or Services with your Personal Information.
Service providers—Super3io may engage, apart from the Developer, certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, order fulfillment, mass mailing, hosting and maintenance, database storage and management, business analytics, and direct marketing campaigns.
Pursuant to written agreements between Super3io and these service providers, each of these service providers only has access to such Personal Information as necessary to fulfill its obligation to the Trainer, is not permitted to use Personal Information for any purposes other than those directed by the Trainer, and is required to act in a manner consistent with the privacy principles articulated in this Privacy Policy and applicable law.
Foreign Distributors—Super3io may provide Personal Information to our distributors in foreign markets. Super3io only do so when we believe that providing such information will permit us to improve the Products or Services provided to Customers in that distributor’s territory, and only when the distributor’s use of such Personal Information is in accordance with the privacy principles described in this Privacy Policy.
To defend or enforce Super3io’s rights—Super3io may use Personal Information to protect itself or to protect the Site, to respond to a breach of its Terms of Service (or other applicable legal terms), to prevent fraudulent activity, or where it is necessary to pursue available remedies. If a Customer neglects to pay amounts due and owing to Super3io, Super3io may send that Customer’s name, contact information, and account information to a third-party service provider for collection of overdue payments.
Joint-Marketing—Super3io may collaborate with other companies to offer you additional Products or Services. Super3io may share Personal Information that is necessary for these other companies to provide the Products or Services that you have requested. This Privacy Policy does not cover the use of your Personal Information by these companies. We encourage you to read a company’s Privacy Policy before requesting any affected Products or Services.
Mergers & Acquisition; Bankruptcy—If any or all of Super3io’s assets are acquired by or merged with those of another entity, or in the unlikely event of a bankruptcy, Super3io may disclose, share or transfer some or all of our users’ personal information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing Super3io’s services to our users. If the recipient of the Personal Information has privacy practices that do not meet the substance of this Privacy Policy, you will be given the opportunity to exercise your rights with respect to your Personal Information.
Law Enforcement; Litigation—Certain federal, state, local, or other government regulations may require that Super3io disclose information that we hold. In such cases, Super3io will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. Super3io may use or disclose Personal Information (a) if we believe in good faith that a law, regulation, rule or guideline requires it; or (b) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person.
Aggregated data—Other than as stated above, if the Trainer provides a third-party with Personal Information, it will be in the form of aggregated data and used for product development, research, or statistical analysis. Aggregated data are created from records that are stripped of all personal identifiers, such as aggregated Assessment responses, or on-site behavior.
The Developer—The Developer may collect, store and process certain Non-personal and Personal Information of the User, solely on Super3io’s behalf and at Super3io’s direction. For example, Super3io is able to import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via their Site. Such contacts are then stored with the Developer, on Super3io’s behalf.
Cookies and Other Technologies
A cookie is a small text file that a website sends to a visitor’s browser and that sends back information each time the visitor makes a request from the website. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. Cookies can be accepted, rejected, or identified by configuring a browser’s preferences or settings. Pixel tags or clear gifs are tiny graphics with a unique identifier that are embedded invisibly on a webpage and are used to track a visitor’s movements on a website. Super3io use the information gathered by clear gifs to help us better manage content on the Site. Cookies and pixel tags are used to help recognize a returning visitor, and to help customize the visitor’s online experience. Unless a visitor specifically informs the Site of his/her identity (e.g., by registering with the Site), Super3io will not know who the individual visitor is.
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The Developer, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve the Site and other services on an ongoing basis, and in order to provide Users with a better experience.
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The Site uses cookies as follows:
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to collect Session Data and other session information;
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to process orders and to store order and shopping cart information;
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to store and hash usernames and passwords so that users do not have to re-enter this information each time they log in; and
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to collect analytics relating to visitors’ use of the Site.
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How Super3io Retain Personal Information
As a general principle, Super3io keep data in personally-identifiable form only for as long as necessary to achieve the purposes for which it is being processed (subject to Super3io’s reasonable archive, backup, and research practices). In practice, that generally means Super3io may retain your Personal Information (i) for as long as your account remains active; (ii) for as long as you continue to do business with us; or (iii) for as long as we are required or permitted to by applicable law. When your account becomes inactive (as determined by Super3io in our sole discretion), or if you cease doing business with us, we may retain your Personal Information for an additional period for our reasonable archive and backup purposes. The duration of Super3io’s retention of your Personal Information may be set forth more specifically in our written agreement(s) with you, or our applicable Terms of Service or other legal terms. At all times, both while you are an active Customer, Practitioner, Respondent, or other registered user and thereafter, Super3io may retain Assessment responses and other data in non-personally-identifiable format for as long as the information is needed for Super3io’s research, statistical analysis, product development, or other commercial purposes.
How We Protect Personal Information
Super3io follow generally-accepted industry standards to protect Personal Information, both during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect Personal Information from unauthorized access, loss, misuse, disclosure, alteration, or destruction.
Super3io’s Developer use industry-standard technological means to protect Personal Information while in transit through the Internet. Super3io’s Developer use encryption and a comprehensive authentication protocol to provide reasonable security.
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No method of transmission over the Internet, or method of electronic storage, is fully secure, however. Therefore, while Super3io and the Developer strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
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Your Rights
Super3io respect your rights as a data subject. In those instances when Super3io are a data controller, we provide you with the rights described below. In those instances where Super3io are a data processor, we will reasonably assist the data controller in facilitating your ability to exercise the rights below.
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Right of access—You have the right to obtain confirmation as to whether or not your Personal Information is being processed. If your Personal Information is being processed, you have the right to access your Personal Information and the following information: (a) the purposes of the processing; (b) the categories of Personal Information concerned; (c) the recipients or categories of recipients to whom your Personal Information has been or will be disclosed (including international organizations and recipients in other countries); (d) where possible, the period for which your Personal Information will be stored or the criteria used to determine that period; (e) the existence of your right to request that the data controller rectify or erase your Personal Information, or restrict processing of your Personal Information, or to object to processing of your Personal Information; (f) your right to lodge a complaint with a supervisory authority; (g) the source of your Personal Information (if it was not obtained from you directly); and (h) the existence of any automated decision-making (including profiling) along with meaningful information about the logic of such automated decision-making and its consequences.
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Right to rectification—You have the right to rectify inaccurate Personal Information concerning you. Taking into account the purposes of the processing, in some instances you will have the right to have incomplete Personal Information completed by providing supplementary written statements to Super3io.
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Right to erasure—You have the right to request erasure of your Personal Information when one of the following applies: (a) your Personal Information is no longer needed to achieve the purpose(s) for which it was originally collected or processed; (b) the processing of your Personal Information is based on your consent, you choose to withdraw that consent, and we have no other legal basis for ongoing processing; (c) you object to the processing and we have no overriding legitimate grounds for ongoing processing; (d) your Personal Information has been processed unlawfully; or (e) your Personal Information must be erased for compliance with applicable law. In those instances where you exercise this right against Super3io as the data controller, we will accommodate your request to the extent practicable, and to the extent that it does not otherwise conflict with any of our other obligations. Super3io reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our contractual agreements.
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Right to restriction of processing—You have the right to restrict processing of your Personal Information where one of the following applies: (a) you contest the accuracy of your Personal Information, in which case processing will be restricted for a period allowing the data controller to verify or rectify the accuracy of your Personal Information; (b) processing of your Personal Information is unlawful; (c) processing of your Personal Information is no longer necessary for the purpose(s) for which it was collected or processed but you require it for the establishment, exercise, or defense of legal claims; or (d) you object to the processing, in which case processing will be restricted for a period allowing the controller to demonstrate whether legitimate grounds exist that override your objection.
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Right to data portability—Where technically feasible, and as related to Personal Information you have provided to a data controller based on your consent or a contract with you, you have the right to receive that Personal Information in a structured, commonly-used and machine-readable format and to transmit that Personal Information to another controller if the processing of that Personal Information is performed by automated means.
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Right to object to processing—In certain instances, you may have the right to object to processing of your Personal Information. Should you so object, the controller of your Personal Information must stop processing your Personal Information unless the controller can demonstrate (i) compelling legitimate grounds for ongoing processing of your Personal Information that override your objection; or (ii) the need for the establishment, exercise, or defense of legal claims.
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Right not to be subject to automated decision-making—In certain instances, you have the right not to be subject to decisions based solely on automated processing (including profiling) that produces legal effects concerning you or otherwise significantly affects you. As of the effective date of this Privacy Policy, we do not engage in any such automated decision-making or profiling.
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Right to opt-out of marketing communications—If you are receiving marketing communications from Super3io and you wish to unsubscribe, you may do so by clicking on the “unsubscribe” link provided in the communication or by managing your marketing communication preferences on the Site).
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Right to block cookies—You have the right to block pixel tags and certain cookies. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our Site cookies, you may not be able to access portions of our Products or Services. Some cookies are strictly necessary for Super3io to deliver the Site or Products or Services, and those cookies cannot be disabled.
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Right to Non-Discrimination—You have the right not to be discriminated against if you choose to exercise your privacy rights. As such, if you choose to exercise your privacy rights Super3io will not: (i) deny you goods or services; (ii) charge you different prices or rates; (iii) provide a different level of service; or (iv) suggest that you will be provided with a different level of service. In some cases, the nature of the product or service you receive may differ depending on whether (or to what extent) you choose to provide Personal Information; however, in those cases there is a direct relationship between the product/service and the Personal Information you provide (for example: if you refuse to provide us with your email address, then our products and services that depend on delivering materials to you via email will not operate as intended).
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California (United States) Privacy Rights—California law requires that individuals be informed when their Personal Information is shared with third parties for these third parties’ direct marketing purposes. Other than as described in this Privacy Policy, we do not disclose your Personal Information to third parties for the direct marketing purposes of these third parties. If our practices change in the future, we will inform you of the change and will provide you with an opportunity to opt out of such information sharing for direct purposes of a third party.
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If Super3io is the controller of your Personal Information and you wish to exercise any of the rights described above, please contact Super3io (located at the Site) with proof of identity. In general, you can expect a response to your request within 30 business days. However, if your request is complex or involves a high volume of data, Super3io may inform you that the request could take up to an additional sixty (60) days. In some instances, fees may apply. If Super3io is not the controller of your Personal Information, we will ask you to direct your request to the data controller, and Super3io will reasonably assist the data controller in facilitating the request.
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Changes to this Privacy Policy
We may change this Privacy Policy from time to time. If we make material changes, we will place a prominent notice on the Site or we will send you a notice to the email address associated with your account.