1. Introduction

Superwonka, Inc. (“Superwonka,” “we,” “us,” or “our”) values your privacy and is committed to protecting personal information in accordance with applicable privacy and data-protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), UK GDPR, California Consumer Privacy Act (“CCPA”), Lei Geral de Proteção de Dados (LGPD – Brazil), and relevant Colombian data-protection laws (Law 1581 of 2012).

This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you access our website, platform, or related services (collectively, the “Service”).

By using the Service, you agree to this Privacy Policy and our Terms of Service.

2. Scope

This Privacy Policy applies to:

• Visitors to our website,

• Users who register for an account, and

• Enterprise customers and their authorized personnel who access our platform.

It does not apply to third-party websites, services, or applications that integrate with Superwonka.

3. Information We Collect

We collect the following categories of information:

a. Account & Contact Information

• Name, email address, phone number, company name, billing details, and user credentials.

b. Usage Data

• Log files, device identifiers, browser type, operating system, IP address, and activity within the Service (pages visited, timestamps, etc.).

c. Customer Data

• Information uploaded or submitted by customers or their employees (e.g., HR, vendor, asset, and facility information).
  Superwonka processes this solely as a data processor on behalf of the customer (the data controller).

d. Payment Information

• Processed securely through third-party payment providers (e.g., Stripe, Paddle). We do not store full payment card numbers.

e. Cookies & Tracking Technologies

• We use cookies and similar tools for authentication, analytics, and product improvement.
  You can adjust cookie preferences through your browser settings.

4. How We Use Information

We use personal information to:

1. Provide, maintain, and improve the Service;

2. Authenticate users and secure access;

3. Process payments and manage subscriptions;

4. Respond to inquiries and provide customer support;

5. Send administrative and marketing communications (where permitted);

6. Comply with legal obligations; and

7. Develop new features and analytics in aggregated, anonymized form.

5. Legal Bases for Processing (GDPR/LGPD)

We process personal data under the following legal bases:

• Performance of Contract — to deliver our Service to customers.

• Legitimate Interest — to secure and improve the platform.

• Consent — for marketing communications or optional cookies.

• Legal Obligation — to comply with tax, audit, or regulatory requirements.

6. Sharing and Disclosure

We may share personal data only as follows:

• Service Providers: cloud hosting, analytics, and payment processors under binding confidentiality and data-processing agreements.

• Affiliates: within the Superwonka corporate group, consistent with this Policy.

• Legal Requirements: where necessary to comply with subpoenas, court orders, or enforce our rights.

• Business Transfers: in the event of a merger, acquisition, or sale of assets, provided the recipient maintains equivalent privacy protections.

We never sell or rent personal information.

7. Data Retention

We retain personal data only as long as necessary to:

• Provide the Service,

• Comply with legal obligations, or

• Resolve disputes.

Customer Data is deleted or returned within 30 days of account termination unless required by law to retain longer.

8. International Data Transfers

Superwonka stores and processes data in the United States and other jurisdictions using industry-standard safeguards, including:

• EU Standard Contractual Clauses (SCCs) for cross-border transfers, and

• Additional measures for Colombian and Brazilian data under local adequacy standards.

By using the Service, you consent to such transfers.

9. Security

We maintain administrative, technical, and physical safeguards aligned with ISO 27001 and SOC 2 Type II best practices.
Measures include encryption in transit and at rest, least-privilege access controls, and continuous monitoring.
However, no method of transmission is 100% secure; you use the Service at your own risk.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete your personal data;

• Withdraw consent for processing;

• Object to or restrict processing;

• Port your data to another controller; and

• File a complaint with a supervisory authority.

Requests may be sent to legal@superwonka.com.
We will respond within legally mandated timeframes (typically 30 days).

11. Children’s Privacy

The Service is not directed at individuals under 16.
We do not knowingly collect personal data from children.
If you believe a child has provided information, contact us to delete it.

12. Marketing Communications

You may opt out of marketing emails at any time by clicking “Unsubscribe” or contacting us directly.
Operational and transactional emails are not subject to opt-out.

13. Third-Party Integrations

The Service may integrate with third-party tools (e.g., Google Workspace, Slack).
Superwonka is not responsible for the privacy practices of such third parties.
We encourage reviewing their respective policies before enabling integrations.

14. Changes to this Policy

We may update this Privacy Policy periodically.
Significant changes will be notified via email or in-app notice.
Continued use of the Service constitutes acceptance of the updated Policy.

15. Contact Information

For questions, requests, or complaints regarding this Privacy Policy, please contact:

Superwonka, Inc.
251 Little Falls Dr
Wilmington, DE
19808, USA
📧 legal@superwonka.com

16. Additional Regional Disclosures

a. California Residents (CCPA)

• You have the right to know, delete, and opt out of the sale of personal data.

• Superwonka does not sell personal data.

• Verification of requests may be required.

b. EU / UK Residents

• Superwonka acts as data processor for Customer Data and data controller for user account data.

• Our Data Protection Officer (DPO) can be contacted at legal@superwonka.com.

c. Colombia / LATAM

• Users may exercise habeas data rights under Law 1581 of 2012 by contacting legal@superwonka.com.

• Data subjects have the right to update, correct, or revoke authorization for data processing.

17. Version Control

This Policy replaces all prior versions.
A historical archive of previous versions is maintained for audit purposes.