Supertone Shift Privacy Policy

Last Revised: September 4, 2024

Article 1 Privacy Notice

This Privacy Policy (this “Policy”) is issued by Supertone, Inc. (“Supertone,” “Company,” “we,” “us,” or “our”) and is addressed to our general customers, visitors to our Sites, users of our Apps and other users of our services (together, “you”). In this Policy, the term “App” means any application made available by us (including where we make such applications available via third-party stores or marketplaces or by any other means), and the term “Site” means any website operated or maintained by us or on our behalf. However, services with their own privacy notice will adhere to their own privacy notice.

As this Policy may be amended or updated from time to time, we encourage you to regularly check this Policy to review any changes to the terms.

The term “personal information,” as used in this Policy, shall mean personal information as defined under Article 2 of the Personal Information Protection Act; for the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”) and the UK Data Protection Act 2018, “personal information” shall mean information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual; and, for the purposes of the California Consumer Privacy Act (the “CCPA”), “personal information” shall be read to also include information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Article 2 Purposes of Processing Personal Information

We process your personal information for the following purposes pursuant to applicable law:

Purposes of Processing

To provide our Sites, Apps, products and services: Providing our Sites, Apps, products or services; creating an account; providing customer support on the use of services; identifying and preventing wrongful uses; providing functions for joining the and for activities; performing statistical analyses; providing promotional materials (upon request); and communicating with you in relation to our Sites, Apps or services, provision and operation of event services (confirming participants for events, providing and delivering prizes to winners, handling other complaints), and providing individually customized products.

To operate our business: Operating and managing our Sites, Apps and services; providing content to you; the identification of uses or other wrongful uses; communicating and interacting with you via our Sites, Apps or services; and notifying you of changes to any of our Sites, Apps or services.

To perform communications and marketing activities: Communicating with you via any means (including via email and app push alerts) to provide news items and other information in which you may be interested, subject to obtaining your prior opt-in consent to the extent required under applicable law; personalizing our Sites, products and services for you; maintaining and updating your contact information where appropriate; where applicable, enabling you to opt-out to withdraw your consent to or unsubscribe from emails sent by us, and recording your choice.

To manage IT systems: Managing and operating our communications, IT and security systems; and auditing (including security audits) and monitoring such systems.

To improve our Sites, Apps and services: Identifying issues related to our Sites, Apps or services; planning improvements to our Sites, Apps or services; and developing new Sites, Apps or services.

Article 3 Processed Personal Information

The personal information that we process about you is as follows:

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