Privacy Policy

Sulie Ltd. (“Sulie”, “we” and/or “us”) respects and exercises your right to control data privacy. We have put in place security measures for your personal data and manage your personal data in accordance with applicable data protection and data privacy regulations. 

Throughout this Privacy Policy the following terms have the following meanings:

• ”Data Privacy Laws” means applicable data protection and data privacy laws and regulations, including but not limited to the EU General Data Protection Regulation (2016/679) (the ”GDPR”).

• “Processing” and “Process” means all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.

• “Personal Data” means Personal Data that relates to you as an identified or identifiable individual.

• “Services“ means our applications and other products, email communications, social media accounts and any related services or properties we control.

This Privacy Policy explains how we collect, use, handle and disclose data when you (a) register or visit our website, www.sulie.co or associated sites or pages (the ”Website”), (ii) engage or communicate with us, (iii) use any of our Services. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Sulie’s business.

While operating the Services, we may share your Personal Data with partners we work with. Some of these partners are Controllers independently of us and, therefore, independently determine how and why they process your data. Further, we may transfer your Personal Data to countries outside the European Economic Area (EEA). Such transfers will be done in accordance with section 5 of this Privacy Policy.

Our Services are not directed to children and we do not knowingly collect Personal Data from children under 16 years of age.

1. Information we collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

Information you provide. We collect personal information that you voluntarily provide to us when you register on the Services or Website, express an interest in obtaining information about us or our Services, or otherwise when you contact us. Information you provide voluntarily when using our Services includes the following data:

• Your name, email address, job title, company name or other contact information communicated to us.

• Any Personal Data provided in any communication channel available in our Services.

• If you have subscribed to our communications, your content preferences or other information you submit to us when subscribing to our communications.

• If you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so.

• Any other information you choose to submit to us through our Services or otherwise.

Information we collect. Sulie collects Personal Data directly from you and/or your device (such as your phone or computer) by automatic means when you use our Services or interact with our advertisements outside of our Services on third-party websites or applications, including through cookies or similar technologies. 

We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offenses or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.

The information we automatically collect includes the following data:

a) Usage information. Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Website or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

Device information. Sulie collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.

Location information. We receive information from you and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Sulie may also collect location information from devices in accordance with the consent process provided by your device.

b) Cookie Information. Sulie uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.

c) Third party data. Sulie may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

2. How do we use your Personal Data?

We use your Personal Data for different purposes. We will for example use the Personal Data to provide you with the Services you have requested, to improve and develop our Services, to predict user trends, to make recommendations and marketing activities based on your usage and to customize our Services to you, these include the following processing activities:

• To perform our contract with you in respect of our Services.

• To understand and analyze how you use our Service and develop new products, Service, features, and functionality;

• To communicate with you, provide you with updates and other information relating to our Service, provide information that you request, respond to comments and questions, and otherwise provide user support;

• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you;

• To find and prevent fraud and respond to trust and safety issues that may arise;

• In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.

• We do not sell to any third party the information we receive or collect from you. 

3. Who might we share your information with?

Your Personal Data may (for the purposes described in this Privacy Policy) be transferred or disclosed to third parties, for the processing of that Personal Data on our behalf, such as to:

• Persons or companies that provide services to us and process data on our behalf when providing those services (for example, services that help us develop and operate our Services and professional advisors).

• Third parties to whom we outsource certain services such software providers, support service providers, cloud infrastructure providers, document and information storage providers.

• Competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation.

• Any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests.

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.

Where required by law, your Personal Data may be disclosed to an applicable governmental, regulatory, sporting or enforcement authority. Your Personal Data may also be disclosed to any regulatory body in connection with prevention and detection of crime and where the Company considers that there are reasonable grounds to suspect that you may be involved in a breach of the law. Those bodies may then use your Personal Data to investigate and act on any such breaches in accordance with their procedures.

4. Data Retention

We will retain your information only for as long as is necessary for the purposes set out in this Privacy Policy. We are using the following criteria to establish our retention period: (i) as long as we have an ongoing relationship with you; (ii) as required by legal obligations to which the Company is subject; and (iii) as advisable in light of our legal position (such as applicable statutes of limitations). For more specific information about data retention terms, please contact our Data Processing Officer privacy@sulie.co and we will provide the specific data retention terms for your jurisdiction.

5. Safeguards to countries outside the EU/EEA-area

In connection with the processing activities described in this Privacy Policy, your data may be transferred to and/or processed in countries outside of the European Union (“EU”) and the European Economic Area (“EEA”). For example, a number of servers we use for hosting data are located in the United States. Where Sulie transfers Personal Data outside the EU/EEA, Sulie will ensure that Standard Contractual Clauses have been entered into between the transferring entity and the receiving external party. Alternatively, other safeguards will be put in place prior to such transfers. You are under Data Privacy Laws upon request entitled to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your Personal Data during a transfer outside the EU/EEA. You can do so by reaching out to our Data Processing Officer at privacy@sulie.co.

6. Security

 We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your Personal Data against unauthorized or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorized access.

7. Your Rights

Individuals located in certain countries, including the European Union (“EU”) European Economic Area (“EEA”), have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this by contacting our Data Processing Officer at privacy@sulie.co. To the extent that Sulie’s processing of your Personal Data is subject to the General Data Protection Regulation (“GDPR”), Sulie relies on its legitimate interests, described above, to process your data. Sulie may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Sulie’s use of your Personal Data for this purpose at any time.

8. Contact Information

Please also feel free to contact Sulie if you have any questions about this Privacy Policy or Sulie’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at hello@sulie.co.