Privacy Policy

Haptivity Technologies Pvt Ltd. offers tools and platform commercialized as “SuperBeings” which provide the means to measure and increase employee commitment by giving them a voice within their organization (the “SuperBeings Platform”). Haptivity Technologies Pvt Ltd. understands the importance of protecting Personal Information (as defined below). For this reason, Haptivity Technologies Pvt Ltd. strives to have business procedures and security safeguards in place to protect Personal Information under its control.

1.

1.1 Application and Scope: This Privacy Policy describes our practices with respect to the collection, use and disclosure of Personal Information by Haptivity Technologies Pvt Ltd. (collectively, “SuperBeings”).

This Privacy Policy (this “Policy“) is intended to establish responsible and transparent practices for the management of Personal Information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Superbeings in respect of any Personal Information collected, accessed or processed by Superbeings in the course of its business operations and specifies the obligations of Superbeings that arise from Superbeings Terms of Service (available at https://www.superbeings.ai/terms-of-use) (the “Terms”) entered into between Superbeings and its corporate customers (each, a “Customer”), whereby Superbeings might handle or have access to Personal Information.

This Policy also governs Personal Information collected about Superbeings’ website Users (as defined in the Terms) and explains how Superbeings uses and discloses Personal Information collected from people who visit its website and otherwise interact with Superbeings through https://superbeings.ai. It also explains how Superbeings uses cookies and similar technologies. If you do not agree with this Policy, do not access, or use the Superbeings Platform and any related services (the “Services”) or the website.

1.2 Definition of Personal InformationPersonal Information” is defined as any information about an identifiable individual. This may include, for example, email addresses and contact details and any similar information provided to Superbeings in the course of its business operations, or which Superbeings may receive from business inquiries. Personal Information that is aggregated and/or de-identified or that cannot be associated with an identifiable individual is not considered to be Personal Information.

1.3 International Compliance Superbeings complies with: (i) data protection laws applicable to Superbeings; (ii) anti-spam legislation applicable to Superbeings; and (iii) applicable industry standards concerning data protection, confidentiality or information security. Superbeings has global operations and therefore, in some cases, information managed by Superbeings may be transferred, processed and stored to other countries, although at all times Superbeings will ensure that Personal Information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Superbeings itself.

Superbeings also complies with the General Data Protection Regulation (Regulation (EU) 2016/679). Where applicable, our commitment to such regulation may be found in our Data Processing Addendum. Superbeings (or third parties acting on Superbeings’ behalf) may transfer Personal Information that Superbeings collects to countries outside of the European Economic Area. Where such transfer occurs, Superbeings will take steps to ensure that Personal Information is protected. Superbeings will make such transfers only if at least one of the following conditions are present:

• Superbeings has entered into a contract based on the “Standard Contractual Clauses”, provided that such contract, combined with technical and organizational measures, offers appropriate safeguards for the rights of the individuals whose personal data is being transferred;

• Such transfer is governed by “Binding Corporate Rules”, which have been approved by data protection authorities; or

• Such transfer is covered by a European Union Commission “adequacy decision”. You can find out more about this here.

1.4 Collection and Use of Personal Information through the Services When providing the Services, Superbeings only processes Personal Information in accordance with the Terms and applicable laws. Superbeings generally uses Personal Information from or about its Customers and Users for the following purposes:

• to create, establish and administer Customer’s account, to process payments, to respond to Customer’s inquiries related to its account and to contact Customer about Superbeings’ Services or account-related matters;

• to provide Services, including to provide Customer and its Users with access and use of the Superbeings Platform and customer support;

• to manage and develop Superbeings’ business and operations;

• to measure and analyze User behavior;

• to monitor, maintain and improve Superbeings’ Services or features;

• to understand how Users interact with Superbeings and ensure our services, products or features work correctly;

• to develop new services, products, features, programs and promotions;

• to understand Customers and Users’ needs and preferences and customize how we tailor and market products, programs and Services to our Customers and Users based on their interest;

• to meet legal and regulatory requirements and to allow Superbeings to meet contractual requirements relating to the Services provided to Customer;

• to conduct surveys on the quality of Superbeings’ Services or to collect feedbacks on the Services;

• to provide Customer with offers for additional services, features and products that Superbeings believes may be of interest to Customer;

• to conduct market or benchmarking research and data analytics by tracking and analyzing current or previously collected Personal Information; and

• to measure the effectiveness of our marketing.

When possible, Superbeings will use Personal Information in an aggregated and/or de-identified format.

Unless required or authorized by law, Superbeings will not use Personal Information for any other or new purpose without obtaining prior consent.

1.5 Collection and Use of Personal Information through the Website Superbeings generally collects and uses Personal Information from or about its website Users as follows:

1.5.1 Information Provided by Users. In many cases, Superbeings collects Personal Information directly from Users when they visit or use the website. For instance, Superbeings may collect the following types of information:

1.5.1.1 Inquiries and Requests for a Trial or Service. Superbeings may collect Users’ name, contact information, email address and any other information provided when Users make an inquiry or contact Superbeings through the website, when Users sign up to receive Superbeings’ newsletter or when Users submit a request or an order for an Superbeings trial or service.

1.5.1.2 Personalization of Website. When Users visit the website, they may, from time to time, be invited to provide information such as User’s title to help Superbeings personalize or customize the Users experience when using the website.

1.5.2 Technical Information. When Users visit the website, Superbeings may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including the IP address of the Users’ computer and which browser was used to view the website, the Users’ operating system, resolution of screen, location, language settings in browsers, the site the User came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the website or enhance the experience for Users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, Superbeings will treat this information as Personal Information. Superbeings may also, without limitations, collect and use the following type of information when Users visit and/or interact with Superbeings on the website:

1.5.2.1 Google Analytics: Superbeings uses Google Analytics which allows it to see information on User website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Superbeings’ use of Google Analytics by visiting the Google Analytics opt-out page.

1.5.2.2 HubSpot: Superbeings uses HubSpot which allows it to see information on User website activities including, but not limited to, page views, source and time spent on our website. However, this information is not depersonalized and Users may not opt-out of Superbeings’ use of HubSpot.

1.5.2.3 Google AdWords: Superbeings uses Google AdWords Remarketing to advertise Superbeings across the Internet and to advertise on third party websites (including Google) to previous visitors of the website. AdWords remarketing will display ads to Users based on what parts of the Superbeings website they have viewed by placing a cookie on the Users’ web browser. It could mean that Superbeings advertises to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the User or give access to the Users’ computer or mobile device. The cookie is only used to indicate to other websites that the User has visited a particular page on the website, so that they may show the User ads relating to that page. If Users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.

1.5.2.4 Interest-based Advertising. Superbeings may also allow a limited number of trusted third parties to install cookies on Users’ hard drive from the website. The website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about Users, such as page views on the website, information requests or purchases on the website. Superbeings does not provide any Personal Information to advertisers or to third party sites that display interest-based ads on the website. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that Users who interact with or click on a personalized ad or content displayed on the website are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the website directly to Users’ browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. Superbeings does not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Policy. Please contact them directly for more information about their privacy practices.

1.5.2.5 Segment: Superbeings uses Segment which allows it to transmit user website activities including, but not limited to, page views, source and time spent on our website to SuperBeings’ data warehouse. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may not opt-out of Superbeings’ use of Segment.

1.5.3 Choice with Cookies. Users can block the use of cookies by activating the settings in their browser. The “Help” feature on most browsers will tell Users how to prevent their browser from accepting new cookies, how to have the browser notify the Users when they receive a new cookie, or how to disable cookies altogether. If Users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, Users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.

1.5.4 Privacy Policies of other Websites. This Policy only addresses the use and disclosure of information by Superbeings. Other websites that may be accessible through the website have their own privacy policies and data collection, use and disclosure practices.

1.5.5 Personal Information from Other Sources. Superbeings may obtain from third parties additional Personal Information about a website User if such User gave permission to those third parties to share its information.

1.6 Sharing of Personal Information Superbeings will not sell, rent or trade Personal Information to any third party. However, Superbeings may share Personal Information when authorized and/or required by law or as follows:

1.6.1 Within Superbeings. We may share Personal Information within Superbeings (i.e. between our affiliates and subsidiaries) in India and US for the purposes described in Sections 4, 5 and 6 of this Policy.

1.6.2 Service Providers. Superbeings may grant access to Personal Information to third-party service providers in connection with the performance or the improvement of its website and Services. Before sharing any Personal Information with any of its third-party service providers, Superbeings will ensure that the third party maintains reasonable data management practices for maintaining the confidentiality and security of Personal Information and preventing unauthorized access.

1.6.3 As Permitted or Required by Law. Superbeings may disclose Personal Information as required by applicable law or by proper legal or governmental authority. Superbeings may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Superbeings may also release certain Personal Information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or safety of others and itself, in accordance with or as authorized by law. In the event Superbeings receives a governmental or other regulatory request for any Personal Information, Superbeings will promptly notify Customer, unless it is prohibited to do so, in order that Customer shall have the option to defend such action. Superbeings shall reasonably cooperate with Customer in such defense.

1.6.4 Business Transaction. Superbeings may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, Personal Information will remain protected by applicable data protection laws. In the event the transaction is not completed, Superbeings will require the other party not to use or disclose the Personal Information received in any manner whatsoever and to delete such Personal Information.

1.6.5 Information through hosting Platforms: SuperBeings provides services that reside inside and consume data from other online platforms (such as Slack or Microsoft Teams, collectively referred to as "Platforms"). When adding the relevant Services to the Platforms, we request permissions which allow sharing of information such as account and profile information or settings of the relevant Platform

1.7 Security of Personal Information Superbeings will store and process the Personal Information in a manner consistent with industry security standards, and as long as necessary for the purposes described in this Policy, unless a longer retention is required by law. Superbeings has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal Information and to mitigate the risk of unauthorized access to or use of Personal Information, including: (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the Personal Information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized Users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with appropriate reasonable up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal Information that it manages; (iv) appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; and (v) permitting only authorized Users access to systems and applications, and all persons with authorized access to Personal Information must have a genuine business need-to-know prior to access (together, “Security Program”).

1.8 Training and Supervision Superbeings maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. Superbeings shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the Personal Information it manages.

1.9 Data Incidents Involving Personal Information Superbeings shall promptly notify Customer of a data breach, of a loss of data or of a failure of Superbeings’ Security Program:

(a) which has resulted or is suspected to have resulted in the loss, unauthorized access, disclosure, use or acquisition of Personal Information (including hard copy records); and

(b) which, in Superbeings’ opinion, presents a real risk of significant harm to individuals whose Personal Information is impacted (“Data Incident”).

While the initial notice may be in a summary form, a comprehensive written notice shall be given to Customer within the legally required timeframe, where applicable. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action taken or to be taken by Superbeings. Superbeings shall promptly take all necessary and advisable corrective actions and shall cooperate with Customer in all reasonable efforts to mitigate the adverse effects of Data Incidents and to prevent their recurrence.

1.10 Users Legal Rights Regarding Personal Information To the extent that Superbeings’ processing of Personal Information is subject to the General Data Protection Regulation (Regulation (EU) 2016/679), Superbeings relies on its legitimate interests, described above, which are not overridden by your data protection interests, to process Personal Information. Subject to applicable laws, Users also have the right to: (i) access and rectification or erasure of Personal Information, to the extent that Superbeings may need to retain certain Personal Information, including for record keeping purposes or to comply with legal obligations; (ii) restrict or object to Superbeings’ use of Personal Information (though, in some cases, this may mean no longer using the Services or the website) where Superbeings is relying on a legitimate interest (or those of a third party) and there is something about User’s particular situation which impacts on User’s fundamental rights and freedoms; (iii) lodge a complaint with their local data protection authority (contact details for data protection authorities in the European Economic Area are available here); and (iv) data portability. Users will not have to pay a fee to exercise such rights, however, Superbeings may charge a reasonable fee or refuse to comply if the request is unfounded, repetitive, or excessive.

1.11 How to Contact Us Any questions or complaints or requests regarding this Policy or Superbeings handling of Personal Information can be addressed by sending an email to hello@superbeings.ai.

A User who seeks to exercise its data protection rights referred to in Section 10, in respect of Personal Information stored or processed by us on behalf of a Customer (e.g. the employer), must direct his/her query to such Customer, as being the data controller. If Superbeings receives such User’s request to exercise its data protection rights referred to in Section 10 (including for access to or correction of Personal Information), Superbeings shall redirect the User to Customer and, upon request from Customer, shall assist Customer in responding to such request, if applicable.

1.12 Change of Privacy Policy Superbeings will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards, and customer concerns. This Policy may therefore change from time to time. If Superbeings makes changes that materially alter Users privacy rights, Superbeings may provide additional notice, such as via email or through the Services or the website. If Users disagree with the terms of this Policy, their only remedy is to discontinue use of the websites and the Services.

This Policy was last updated on February 14, 2021.

Haptivity Technologies Pvt Ltd. offers tools and platform commercialized as “SuperBeings” which provide the means to measure and increase employee commitment by giving them a voice within their organization (the “SuperBeings Platform”). Haptivity Technologies Pvt Ltd. understands the importance of protecting Personal Information (as defined below). For this reason, Haptivity Technologies Pvt Ltd. strives to have business procedures and security safeguards in place to protect Personal Information under its control.

1.

1.1 Application and Scope: This Privacy Policy describes our practices with respect to the collection, use and disclosure of Personal Information by Haptivity Technologies Pvt Ltd. (collectively, “SuperBeings”).

This Privacy Policy (this “Policy“) is intended to establish responsible and transparent practices for the management of Personal Information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Superbeings in respect of any Personal Information collected, accessed or processed by Superbeings in the course of its business operations and specifies the obligations of Superbeings that arise from Superbeings Terms of Service (available at https://www.superbeings.ai/terms-of-use) (the “Terms”) entered into between Superbeings and its corporate customers (each, a “Customer”), whereby Superbeings might handle or have access to Personal Information.

This Policy also governs Personal Information collected about Superbeings’ website Users (as defined in the Terms) and explains how Superbeings uses and discloses Personal Information collected from people who visit its website and otherwise interact with Superbeings through https://superbeings.ai. It also explains how Superbeings uses cookies and similar technologies. If you do not agree with this Policy, do not access, or use the Superbeings Platform and any related services (the “Services”) or the website.

1.2 Definition of Personal InformationPersonal Information” is defined as any information about an identifiable individual. This may include, for example, email addresses and contact details and any similar information provided to Superbeings in the course of its business operations, or which Superbeings may receive from business inquiries. Personal Information that is aggregated and/or de-identified or that cannot be associated with an identifiable individual is not considered to be Personal Information.

1.3 International Compliance Superbeings complies with: (i) data protection laws applicable to Superbeings; (ii) anti-spam legislation applicable to Superbeings; and (iii) applicable industry standards concerning data protection, confidentiality or information security. Superbeings has global operations and therefore, in some cases, information managed by Superbeings may be transferred, processed and stored to other countries, although at all times Superbeings will ensure that Personal Information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Superbeings itself.

Superbeings also complies with the General Data Protection Regulation (Regulation (EU) 2016/679). Where applicable, our commitment to such regulation may be found in our Data Processing Addendum. Superbeings (or third parties acting on Superbeings’ behalf) may transfer Personal Information that Superbeings collects to countries outside of the European Economic Area. Where such transfer occurs, Superbeings will take steps to ensure that Personal Information is protected. Superbeings will make such transfers only if at least one of the following conditions are present:

• Superbeings has entered into a contract based on the “Standard Contractual Clauses”, provided that such contract, combined with technical and organizational measures, offers appropriate safeguards for the rights of the individuals whose personal data is being transferred;

• Such transfer is governed by “Binding Corporate Rules”, which have been approved by data protection authorities; or

• Such transfer is covered by a European Union Commission “adequacy decision”. You can find out more about this here.

1.4 Collection and Use of Personal Information through the Services When providing the Services, Superbeings only processes Personal Information in accordance with the Terms and applicable laws. Superbeings generally uses Personal Information from or about its Customers and Users for the following purposes:

• to create, establish and administer Customer’s account, to process payments, to respond to Customer’s inquiries related to its account and to contact Customer about Superbeings’ Services or account-related matters;

• to provide Services, including to provide Customer and its Users with access and use of the Superbeings Platform and customer support;

• to manage and develop Superbeings’ business and operations;

• to measure and analyze User behavior;

• to monitor, maintain and improve Superbeings’ Services or features;

• to understand how Users interact with Superbeings and ensure our services, products or features work correctly;

• to develop new services, products, features, programs and promotions;

• to understand Customers and Users’ needs and preferences and customize how we tailor and market products, programs and Services to our Customers and Users based on their interest;

• to meet legal and regulatory requirements and to allow Superbeings to meet contractual requirements relating to the Services provided to Customer;

• to conduct surveys on the quality of Superbeings’ Services or to collect feedbacks on the Services;

• to provide Customer with offers for additional services, features and products that Superbeings believes may be of interest to Customer;

• to conduct market or benchmarking research and data analytics by tracking and analyzing current or previously collected Personal Information; and

• to measure the effectiveness of our marketing.

When possible, Superbeings will use Personal Information in an aggregated and/or de-identified format.

Unless required or authorized by law, Superbeings will not use Personal Information for any other or new purpose without obtaining prior consent.

1.5 Collection and Use of Personal Information through the Website Superbeings generally collects and uses Personal Information from or about its website Users as follows:

1.5.1 Information Provided by Users. In many cases, Superbeings collects Personal Information directly from Users when they visit or use the website. For instance, Superbeings may collect the following types of information:

1.5.1.1 Inquiries and Requests for a Trial or Service. Superbeings may collect Users’ name, contact information, email address and any other information provided when Users make an inquiry or contact Superbeings through the website, when Users sign up to receive Superbeings’ newsletter or when Users submit a request or an order for an Superbeings trial or service.

1.5.1.2 Personalization of Website. When Users visit the website, they may, from time to time, be invited to provide information such as User’s title to help Superbeings personalize or customize the Users experience when using the website.

1.5.2 Technical Information. When Users visit the website, Superbeings may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including the IP address of the Users’ computer and which browser was used to view the website, the Users’ operating system, resolution of screen, location, language settings in browsers, the site the User came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the website or enhance the experience for Users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, Superbeings will treat this information as Personal Information. Superbeings may also, without limitations, collect and use the following type of information when Users visit and/or interact with Superbeings on the website:

1.5.2.1 Google Analytics: Superbeings uses Google Analytics which allows it to see information on User website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Superbeings’ use of Google Analytics by visiting the Google Analytics opt-out page.

1.5.2.2 HubSpot: Superbeings uses HubSpot which allows it to see information on User website activities including, but not limited to, page views, source and time spent on our website. However, this information is not depersonalized and Users may not opt-out of Superbeings’ use of HubSpot.

1.5.2.3 Google AdWords: Superbeings uses Google AdWords Remarketing to advertise Superbeings across the Internet and to advertise on third party websites (including Google) to previous visitors of the website. AdWords remarketing will display ads to Users based on what parts of the Superbeings website they have viewed by placing a cookie on the Users’ web browser. It could mean that Superbeings advertises to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the User or give access to the Users’ computer or mobile device. The cookie is only used to indicate to other websites that the User has visited a particular page on the website, so that they may show the User ads relating to that page. If Users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.

1.5.2.4 Interest-based Advertising. Superbeings may also allow a limited number of trusted third parties to install cookies on Users’ hard drive from the website. The website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about Users, such as page views on the website, information requests or purchases on the website. Superbeings does not provide any Personal Information to advertisers or to third party sites that display interest-based ads on the website. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that Users who interact with or click on a personalized ad or content displayed on the website are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the website directly to Users’ browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. Superbeings does not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Policy. Please contact them directly for more information about their privacy practices.

1.5.2.5 Segment: Superbeings uses Segment which allows it to transmit user website activities including, but not limited to, page views, source and time spent on our website to SuperBeings’ data warehouse. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may not opt-out of Superbeings’ use of Segment.

1.5.3 Choice with Cookies. Users can block the use of cookies by activating the settings in their browser. The “Help” feature on most browsers will tell Users how to prevent their browser from accepting new cookies, how to have the browser notify the Users when they receive a new cookie, or how to disable cookies altogether. If Users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, Users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.

1.5.4 Privacy Policies of other Websites. This Policy only addresses the use and disclosure of information by Superbeings. Other websites that may be accessible through the website have their own privacy policies and data collection, use and disclosure practices.

1.5.5 Personal Information from Other Sources. Superbeings may obtain from third parties additional Personal Information about a website User if such User gave permission to those third parties to share its information.

1.6 Sharing of Personal Information Superbeings will not sell, rent or trade Personal Information to any third party. However, Superbeings may share Personal Information when authorized and/or required by law or as follows:

1.6.1 Within Superbeings. We may share Personal Information within Superbeings (i.e. between our affiliates and subsidiaries) in India and US for the purposes described in Sections 4, 5 and 6 of this Policy.

1.6.2 Service Providers. Superbeings may grant access to Personal Information to third-party service providers in connection with the performance or the improvement of its website and Services. Before sharing any Personal Information with any of its third-party service providers, Superbeings will ensure that the third party maintains reasonable data management practices for maintaining the confidentiality and security of Personal Information and preventing unauthorized access.

1.6.3 As Permitted or Required by Law. Superbeings may disclose Personal Information as required by applicable law or by proper legal or governmental authority. Superbeings may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Superbeings may also release certain Personal Information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or safety of others and itself, in accordance with or as authorized by law. In the event Superbeings receives a governmental or other regulatory request for any Personal Information, Superbeings will promptly notify Customer, unless it is prohibited to do so, in order that Customer shall have the option to defend such action. Superbeings shall reasonably cooperate with Customer in such defense.

1.6.4 Business Transaction. Superbeings may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, Personal Information will remain protected by applicable data protection laws. In the event the transaction is not completed, Superbeings will require the other party not to use or disclose the Personal Information received in any manner whatsoever and to delete such Personal Information.

1.7 Security of Personal Information Superbeings will store and process the Personal Information in a manner consistent with industry security standards, and as long as necessary for the purposes described in this Policy, unless a longer retention is required by law. Superbeings has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal Information and to mitigate the risk of unauthorized access to or use of Personal Information, including: (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the Personal Information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized Users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with appropriate reasonable up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal Information that it manages; (iv) appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; and (v) permitting only authorized Users access to systems and applications, and all persons with authorized access to Personal Information must have a genuine business need-to-know prior to access (together, “Security Program”).

1.8 Training and Supervision Superbeings maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. Superbeings shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the Personal Information it manages.

1.9 Data Incidents Involving Personal Information Superbeings shall promptly notify Customer of a data breach, of a loss of data or of a failure of Superbeings’ Security Program:

(a) which has resulted or is suspected to have resulted in the loss, unauthorized access, disclosure, use or acquisition of Personal Information (including hard copy records); and

(b) which, in Superbeings’ opinion, presents a real risk of significant harm to individuals whose Personal Information is impacted (“Data Incident”).

While the initial notice may be in a summary form, a comprehensive written notice shall be given to Customer within the legally required timeframe, where applicable. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action taken or to be taken by Superbeings. Superbeings shall promptly take all necessary and advisable corrective actions and shall cooperate with Customer in all reasonable efforts to mitigate the adverse effects of Data Incidents and to prevent their recurrence.

1.10 Users Legal Rights Regarding Personal Information To the extent that Superbeings’ processing of Personal Information is subject to the General Data Protection Regulation (Regulation (EU) 2016/679), Superbeings relies on its legitimate interests, described above, which are not overridden by your data protection interests, to process Personal Information. Subject to applicable laws, Users also have the right to: (i) access and rectification or erasure of Personal Information, to the extent that Superbeings may need to retain certain Personal Information, including for record keeping purposes or to comply with legal obligations; (ii) restrict or object to Superbeings’ use of Personal Information (though, in some cases, this may mean no longer using the Services or the website) where Superbeings is relying on a legitimate interest (or those of a third party) and there is something about User’s particular situation which impacts on User’s fundamental rights and freedoms; (iii) lodge a complaint with their local data protection authority (contact details for data protection authorities in the European Economic Area are available here); and (iv) data portability. Users will not have to pay a fee to exercise such rights, however, Superbeings may charge a reasonable fee or refuse to comply if the request is unfounded, repetitive, or excessive.

1.11 How to Contact Us Any questions or complaints or requests regarding this Policy or Superbeings handling of Personal Information can be addressed by sending an email to hello@superbeings.ai.

A User who seeks to exercise its data protection rights referred to in Section 10, in respect of Personal Information stored or processed by us on behalf of a Customer (e.g. the employer), must direct his/her query to such Customer, as being the data controller. If Superbeings receives such User’s request to exercise its data protection rights referred to in Section 10 (including for access to or correction of Personal Information), Superbeings shall redirect the User to Customer and, upon request from Customer, shall assist Customer in responding to such request, if applicable.

1.12 Change of Privacy Policy Superbeings will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards, and customer concerns. This Policy may therefore change from time to time. If Superbeings makes changes that materially alter Users privacy rights, Superbeings may provide additional notice, such as via email or through the Services or the website. If Users disagree with the terms of this Policy, their only remedy is to discontinue use of the websites and the Services.

This Policy was last updated on February 14, 2021.