Suvoda.com Privacy Policy

Suvoda LLC, a U.S. company with corporate domicile at 181 Washington Street, Suite 100, Conshohocken, PA 19428, USA, and its affiliates (hereinafter collectively referred to as “Suvoda”, “We”, “Our”, “Us”) provides clinical trial software, payment, travel and related services, including Suvoda IRT, eConsent, eCOA, Scheduling, Greenphire Travel, Greenphire Patient Payments, Budgeting and Benchmarking, and Site Payments (collectively, our "Services") and operates the website at www.suvoda.com (the “Site”).  In the course of providing the Services and operating the Site as well as delivering commercial information, software and email updates, we collect and process information about people visiting our Site, our customers, our customers’ authorized users of our Services, as well as from our vendors and leads. Some of such information may be personal information and could be related to an identified or identifiable natural person (the "Personal Information"). This privacy policy (the "Privacy Policy") explains how We, as data controllers, collect, use, share and protect such Personal Information about you as someone who uses the Services or may be interested in the Services or accesses or uses the Site. It also explains what your choices are regarding the collection, use and sharing of your information.

If you are a resident of California, please refer to Section 13 California Notice at Collection and Privacy Policy, which includes additional information about the personal information that we may collect about you, and your rights under California privacy laws.

By contacting Suvoda because of the Services and/or using the Site you are hereby informed of the scope of this Privacy Policy. We encourage you to read it carefully.

Table of Contents

  1. Scope
  2. Information We Collect
  3. How We Use the Personal Information Collected
  4. How We Share the Personal Information Collected
  5. Security and Information Protection
  6. Policy Regarding Children
  7. Third Party Links
  8. Your Privacy Choices
  9. Retention
  10. Cross Border Transfer
  11. Changes to Privacy Policy
  12. Complaints, Questions or Comments
  13. California Notice at Collection and Privacy Policy

 

  1. Scope

This Privacy Policy applies to Personal Information We collect and process from you to carry out the following activities:

  • Interact with you because of your interest in our Services as a prospective customer ("Leads") or as a vendor (“Vendor”)
  • Provide you with access to our Services ("Customers") or information about or services (“Clinical Trial Participants”)
  • Evaluate job applications and contact candidates (“Applicants”)
  • Interact with you by e-mail, text and other electronic messages

This Privacy Policy does not apply to information:

  • Collected by any third party, including through any application or content that may link to or be accessible from the Site. We encourage you to carefully review the privacy policies of any third party services you access.
  • Collected by the Suvoda IRT, eConsent, eCOA, Scheduling, Greenphire Travel, Greenphire Patient Payments, Budgeting and Benchmarking, or Site Payment services.
  • Collected or processed by Us in our capacity as a service provider to our Customers. In general, we process information that we receive in our capacity as a service provider for the purposes for which our Customer provided the information and subject to our contract with the particular Customer. Please note that we may also use information, including personal information, that we have collected and/or processed on behalf of our Customer in our capacity as a service provider where we believe it is required or permitted by law or necessary to protect the security of our Services, our rights and interests, and/or the rights and interests of other persons.

 

Legal bases for processing:

 

Our legal basis for processing Personal Information depends on the Personal Information involved and the context in which we process it. Where Greenphire acts as a data controller, we process your Personal Information: with your consent; where necessary to perform a contract; to comply with our legal obligations; and where doing so is in our legitimate interests (including the purposes described in this Notice) and such interests are not outweighed by your rights and freedoms.

  1. Personal Information We Collect:

We may collect and store the following categories of Personal Information from you:

Information Provided in Forms:

In order to use some of the Services and/or the Site, including commenting on our blog and downloading content, you will need to provide information such as your first name, last name, email, URL address, telephone number, company name and role in the company and you may elect to provide other information from time to time including, for instance, dietary restrictions for events Suvoda may host.

Usage, Log, Cookies:

When you use our Site, We, or our third-party providers, may use a variety of technologies that collect information about how you use and access the Site and/or Services. This is described in more detail in our Cookies Policy at https://www.suvoda.com/cookie-policy. We encourage you to carefully read it in order to be properly be informed on the scope of the data processing We may do because of using Cookies.

We may collect information from your interaction with the Site, including from the following:

  • Feedback and email communications you send us: Any feedback, questions, comments, suggestions, ideas, or the like that you send to Us. These will be treated as non-confidential and non-proprietary and We may use them and share them with third parties. We collect the email addresses of those who communicate with Us by email. We may record your inquiries in our database.
  • Interactions with Emails sent to you: Information on your interaction with emails sent to you in connection with the Site and Services, including when you open and act upon Our emails including clicking links in them.
  • Activity data: This includes information, such as the time of an event, how you came to the Site, what search engine and search keywords you may have used to get to the Site, your activities on the Site including: pages visited, referring sites, forms submitted on the Site and the submission time, social media username and information about your activities in your social media accounts, including: clicks, username, bio, and friends or followers.
  • Device Information: Information about the device you are using such as, hardware model, operating system, application version number and browser, mobile network information, IP addresses, user names, real names, email addresses and other custom properties.
  • Log Information: Server logs regarding how you use the Site or view content provided by applicable analytics providers such as Google, Hubspot and Microsoft,       which may include: Google search queries, hardware settings, browser type, browser language, the date and time of your request and referral URL, sources from which you arrived to Our Site (web page, email, etc.); cookies that may uniquely identify you or your browser.
  • Location Information: Information about your estimated location which may be deduced by various technologies including your IP address.

Hubspot:

We use a tool called “Hubspot” to collect some information we listed above about your use of the Site. We use the information we get from Hubspot to improve the Site and our Services.  In order to collect this information, Hubspot may set cookies on your browser or mobile device, or read cookies that are already there. Hubspot is prohibited from using your information, except as necessary to provide and improve its services to Suvoda, as permitted by its Privacy Policy available at https://legal.hubspot.com/privacy-policy, and as required by law.

Social Media Features:

Our website includes Social Media Plugins and Widgets (“Features”). These Features may collect your IP address, which page you are visiting on Our Site, the date and time of your visit, and other browser- and device-related information whether or not you are logged into the relevant Social Media account. If you are logged into the relevant Social Media account, this data may be associated with your user name. The Features may also set cookies to enable them to function. This information may be used by the parties providing such Features for advertising purposes. The Features are either hosted by a third party or hosted directly on Our Site. Your interactions with these features are governed by the privacy policies of the relevant social media networks whose Features are included on the Site.  Please see these policies for more information about the collection and use of your information by these Features.  Please see the "Your Privacy Choices" Section below to see some ways you may opt out of certain targeted advertising.

  1. How We Use the Personal Information Collected?

We may use the information We collect, including Personal Information, in the following ways (purposes of the data processing):

  • To provide you with the Site and/or our Services and comply with Our contractual and legal obligations.
  • To contact you by telephone, post mail, email or any other electronic mean in relation to your use of, or interest in, the Site and/or Services.
  • To send you commercial communications, including through electronic means such as email, about additional products or services that may be of interest to you.
  • To communicate with you about the Services by email or any other electronic means.
  • For the specific purpose for which the information was provided.
  • To provide you with customer related services, such as to help diagnose problems with Our server and to administer the Site or to address technical issues.
  • To generate aggregate statistical studies that could help Us to improve our Site and/or Services.
  • To contact you in relation to your expressed interest in an open employment position
  • To prevent or detect fraud.
  • In an emergency or to protect the safety of any person.
  • To enforce the Terms of Use for this Site (http://www.suvoda.com/terms-of-use), including to protect the rights, property, or safety of Suvoda, its users, or any other person, or the copyright-protected content of the Services.
  • To investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person, as well as regarding situations that involve abuse of the Services infrastructure or the Internet in general.
  • As required by law or regulation, or as requested by government authorities, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands, or to comply with requirements of mandatory applicable law.
  • To analyze how you use the Site, including how you interact with applications, advertising, products, and services that are made available, linked to, or offered through the Site.
  • To consider and implement mergers, acquisitions, reorganizations, consolidations, changes of control or sale of all or a portion of our assets, bankruptcies or liquidations and other transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

We appreciate the importance of your privacy, so in the event you wish to stop receiving commercial communications related to our Services, please let us know. You can send an email to privacy@suvoda.com at any time requesting to unsubscribe from our distribution list.

  1. How We Share the Personal Information Collected:

Information on Public Areas of the Site:

If you choose to comment on a blog or otherwise participate in a discussion on a public area of the Site, please remember that any information that you disclose in these areas becomes public information. You should exercise caution when deciding whether or not to disclose your personal information.

Service Providers/Contractors:

We may share your Personal Information with service providers/contractors to perform functions and process your data, consistent with this Privacy Policy, in order to help Us provide Our Site and Services. For example, we work with providers such as Hubspot.  For our mailings, Our third-party providers may have access to information we provide to them including your email address, as well as to the content of emails We send to you. Emails sent to you in connection with the Site and/or Services may include single pixel gifs, also called web beacons. They provide our third-party providers access to the information listed above under "Emails sent to you". For the production of reports to improve our Site, these third party providers may get access to information listed above under "Activity Data" and "Log Information". We also work with providers such as Salesforce to host Our database. We share with them the information listed under "Information provided in forms" above.

Other Sharing:

In addition to the uses described above, We may also share your information with third parties for the following purposes:

  • When you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing
  • To a parent company, subsidiaries, joint ventures, or other companies under common control with us.
  • In connection with a merger, acquisition, consolidation, change of control or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation.
  • Where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands, or to comply with requirements of mandatory applicable law
  • If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person
  • In an emergency or to protect the safety of any person
  • If we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the website infrastructure or the Services generally)
  • To prevent or detect fraud or to address technical issues
  • To enforce this Privacy Policy, the Terms of Use (http://www.suvoda.com/terms-of-use) and any other terms that you have agreed to, including to protect the rights, property, or safety of Suvoda, its users, or any other person, or the copyright-protected content of the Services;
  • We may also share de-identified or aggregated information about you with third parties, including with academic researchers for purposes including statistical analysis and academic study.

Please see our Cookies Policy https://www.suvoda.com/cookie-policy for information about the technologies that we and third parties use to collect information and to learn about options in connection with these.

  1. Security and Information Protection

We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

  1. Policy Regarding Children

Our website is intended for use by a general audience and is not directed to children. We do not knowingly collect information from children through the use of the Site, nor do We use or disclose personal information of children in connection with providing the Site.

If you become aware that We have inadvertently collected personal information from a child without the necessary consent required by applicable law, please contact Us at privacy@suvoda.com and we will take steps to promptly delete that information. If you are a California resident under the age of 18 and wish to remove publicly available content, please contact Us at privacy@suvoda.com.

  1. Third Party Links

The Site may contain links to third party sites that are not owned or controlled by Suvoda. We have no control over the content, privacy policies, or practices of any third party site. You are subject to the policies of those third party sites where applicable. We encourage you to ask questions before you disclose your Personal Information to those third parties.

  1. Your Privacy Choices

If you want to exercise your privacy choices as a data subject including, without limitation, to access and/or request an update, correction, or a copy of the Personal Information we may have collected from you, please write to Us at privacy@suvoda.com. Depending on your location, you may have the following rights with respect to your Personal Information under applicable data protection laws:

  • Access – The right to request access to and obtain a copy of any Personal Information we may have about you;
  • Deletion – The right to delete the Personal Information that we have collected or obtained from you, subject to certain exceptions;
  • Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions;
  • Opt Out of Certain Processing - The right to: (a) opt out of the processing of your Personal Information for purposes of targeted advertising, (b) opt out of the sale or sharing of your Personal Information; (c) limit the use of your sensitive Personal Information (if applicable), and (c) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not collect or process sensitive Personal Information outside of purposes permitted by law (such as section 7027(m) under the California Consumer Privacy Act Regulations), so we do not offer the option to limit its use. We also do not profile you or other individuals in a manner that would result in legal or similarly significant effects, so we do not offer an opt out.
  • Objection/Restriction of Processing - The right to object or restrict us from processing your Personal Information in certain circumstances.
  • Withdraw Consent - The right to withdraw your consent where we are relying on your consent to process your Personal Information. You may also have the right to obtain information on the possibility of not providing consent and on the consequences of such denial.
  • Automated Decision-Making - The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right to consent or opt out of this automated decision-making, depending on your location.
  • Lodge a Complaint - The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

You may opt out of receiving promotional email communications regarding our Services and activities by clicking the "unsubscribe" link provided with each email or by sending an email to privacy@suvoda.com requesting us to stop sending you such emails. We may continue to send you non-promotional notifications in connection with the Services.  

You may exercise your privacy choices by writing us at privacy@suvoda.com. Please identify yourself in such communication and provide us with a copy of your passport or ID card so we can properly verify your identity. If you make such request, we will respond to you within a reasonable time and, where appropriate, fulfill your request.

We will endeavor to respond to your request; however, we may not be able to fulfill your request in all circumstances.

For any privacy or data-protection-related questions, please write to privacy@suvoda.com.

  1. Retention

We will retain your Personal Information only during the time period that it is necessary to provide you with the Services and/or to comply with corresponding laws and regulations. Therefore, we will retain your Personal Information until the earlier of (i) the information is no longer necessary to accomplish the purpose for which it was provided; or (ii) you have requested that we delete your Personal Information as stated above. We may retain your information for longer periods to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or we reasonably believe that retaining the information is necessary to protect our legal rights or legitimate business interests. In those cases, the Personal Information will be segregated such that no active data processing will take place and the Personal Information will merely be stored and retained to comply with the corresponding applicable laws or regulations.

 

  1. Cross Border Transfer

Suvoda transfers, processes, and stores information about you on servers located in a number of countries, including the United States, which countries do not offer an equivalent level of protection on privacy matters that is offered in other territories such as the European Union. We may also subcontract processing to, or share your information with, third parties located in countries other than your home country.

Transfers of Information from the EEA

Suvoda complies with the EU-U.S. Data Privacy Framework program (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (“Swiss-U.S. DPF” and together with the EU-U.S. DPF, the “DPF”) as set forth by the U.S. Department of Commerce. Suvoda has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Suvoda has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program principles (“Swiss-U.S. DPF Principles” and together with the EU-U.S. DPF Principles, the “DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the applicable DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

When we receive personal information under the DPF and then transfer it to third party service providers, we are liable for any processing of personal information by such third parties that is inconsistent with the DPF Principles unless we are not responsible for the event giving rise to any alleged damage.

Under the DPF you are entitled to access, correct, amend, or delete personal information about you that we hold where it is inaccurate, or has been processed in violation of the DPF Principles. You may access, amend, correct or delete your registration information by accessing your account on the Site. You may also exercise this right by contacting us at privacy@suvoda.com.

With respect to personal data received or transferred pursuant to the DPF, Suvoda is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

In certain situations, Suvoda may be required to disclose personal data in response to lawful requests by public authorities, including in order to meet national security or law enforcement requirements.  For more information, please see the "How We Share the Information Collected" section above.

In compliance with the EU-US DPF Principles, Suvoda commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact Suvoda at suvoda@privacy.com or as set forth under the Section titled “Complaints, Questions or Comments” below.

Suvoda has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

Other Cross Border Transfers

In connection with the cross-border transfer of your personal information, including to the United States, your Personal Information may be subject to privacy laws that may not provide the same protection as your country of residence. For example, government entities in the United States and other countries may have certain rights to access your Personal Information. By using the Services you are consenting to this transfer of your personal information.

  1. Changes to Privacy Policy

This Privacy Policy is subject to revisions from time to time, in our sole discretion. When we make changes we deem material, we will provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Site. In some cases, we will notify you in advance of the changes taking effect. Your continued use of the Services and the Site after the changes have been made will constitute your acceptance of the changes. Please, therefore, make sure you read any such notice carefully. If you do not wish your Personal Information to continue being processed under the new version of the Privacy Policy, please cease using the Site and Services.

  1. Complaints, Questions or Comments

We welcome questions and comments about this Privacy Policy.  Questions or comments should be directed to us in accordance with the contact details provided below.

We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of Personal Information in accordance with the provisions of this Privacy Policy.


Suvoda LLC

181 Washington Street, Suite 100

Conshohocken, PA 19428

ATTN: Privacy Officer

1-855-788-6321

Email: privacy@suvoda.com

 

Suvoda SRL

10 Bld I.C. Bratianu, Floor 3, District 3

Bucharest, Romania, 011413

ATTN: Privacy Officer

0800-896-362

Email: privacy@suvoda.com

  1. California Notice at Collection and Privacy Policy

This California Notice at Collection and Privacy Policy (“Policy”) is for California residents and describes our information practices pursuant to applicable privacy laws, including the California Consumer Privacy Act and the regulations issued thereto, each as amended (“CCPA”). To the extent you are a California resident, and we collect “personal information” subject to the CCPA, the following applies.

This Policy does not address or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information or deidentified or aggregated information. This Policy also does not apply to personal information that we collect and process about employees, contractors, personnel, job applicants, or candidates.

Categories of Personal Information Collected and Disclosed. The table below identifies, generally, the categories of personal information we have collected about California residents, as well as the categories of third parties to whom we may disclose this personal information for a business or commercial purpose.

Categories of Personal Information Collected

Categories of Third Party Disclosures

Identifiers. Such as name, alias, email, phone number, address, user ID username, unique personal identifier, online identifier, IP address, or other similar identifiers.
  • Advisors and agents;
  • Affiliates and subsidiaries;
  • Advertising networks;
  • Data analytics providers;
  • Social networks;
  • Internet service providers, operating systems, and platforms;
  • Regulators, government entities and law enforcement; and
  • Others with your permission or as required by law.

Internet and electronic network activity information. Such as browsing history, clickstream data, search history, and information regarding interactions with our Site, advertisements, or emails, including other or other online services.
  • Advisors and agents;
  • Advertising networks;
  • Data analytics providers;
  • Social networks;
  • Internet service providers, operating systems, and platforms;
  • Regulators, government entities and law enforcement; and
  • Others with your permission or as required by law.

Geolocation Data. Such as general location information about a particular individual or device (i.e., via your IP address).
  • Advisors and agents;
  • Affiliates and subsidiaries;
  • Advertising networks;
  • Data analytics providers;
  • Social networks;
  • Internet service providers, operating systems, and platforms;
  • Regulators, government entities and law enforcement; and
  • Others with your permission or as required by law.

Professional information. Such as job title, company name, business email, business phone number, and other similar professional-related information.
  • Advisors and agents;
  • Affiliates and subsidiaries;
  • Internet service providers, operating systems, and platforms;
  • Regulators, government entities and law enforcement; and
  • Others with your permission or as required by law.

Education Information. Such as degrees earned, educational institutions attended, transcripts, training records, and other information about your educational history or background that is not publicly available personally identifiable information as defined under the Family Educational Rights and Privacy Act.
  • Advisors and agents;
  • Affiliates and subsidiaries;
  • Internet service providers, operating systems, and platforms;
  • Applicant tracking systems

 

Inferences. Such as inferences drawn from any of the information described in this section to create a profile about a consumer (California resident) reflecting the consumer’s preferences, characteristics, behaviors, attitudes, intelligence, abilities, and aptitudes.
  • Advisors and agents;

·      Affiliates and subsidiaries;

·      Regulators, government entities, and law enforcement;

·      Data analytics providers;

·      Internet service providers; operating systems, and platforms;

·      Advertising networks; and

  • Others with your permission or as required by law.

Protected Classifications. Such as age, sex, and other characteristics of protected classifications under California or federal law.
  • Advisors and agents;
  • Affiliates and subsidiaries;
  • Regulators, government entities, and law enforcement; and
  • Others with your permission or as required by law.

Sensitive Personal Information. In limited circumstances, we may collect: driver’s license, state identification card, or passport number.
  • Advisors and agents;
  • Affiliates and subsidiaries;
  • Regulators, government entities, and law enforcement; and
  • Internet service providers, operating systems, and platforms;
  • Applicant tracking systems
  • Others with your permission or as required by law.

 

Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers; commercial information; location data (via your IP address); and internet or other electronic network activity information. We may disclose these categories to third-party advertising networks, analytics providers, social networks, and data brokers for purposes of marketing and advertising and to improve and measure our ad campaigns.

We do not sell or share sensitive personal information, nor do we sell or share personal information about individuals we know are under age sixteen (16).

Sources of Personal Information. We generally collect personal information from the following categories of sources: directly or indirectly from you; affiliates and subsidiaries; Customers; vendors and service providers; data brokers, social networks, and marketing and data analytics providers.

Purposes of Collection, Use, and Disclosure. As further described in Section 3 of the Privacy Policy, How We Use the Personal Information Collected, and Section 4 of the Privacy Policy, How We Share the Personal Information Collected, we may collect, use, disclose, and otherwise process the above listed personal information for the following business or commercial purposes and as otherwise directed or consented to by you:

  • To provide you with the Site and/or Our Services and comply with Our contractual and legal obligations.
  • To contact you by telephone, post mail, email or any other electronic mean in relation to your use of the Site and/or Services.
  • To send you commercial communications, including through electronic means such as email, about additional products or services that may be of interest to you.
  • To communicate with you about the Services by email or any other electronic means.
  • For the specific purpose for which the information was provided.
  • To provide you with customer related services, such as to help diagnose problems with Our server and to administer the Site or to address technical issues.
  • To generate aggregate statistical studies that could help us to improve our Site and/or Services.
  • To contact you in relation to your expressed interest in an open employment position
  • To prevent or detect fraud.
  • In an emergency or to protect the safety of any person.
  • To enforce the Terms of Use for this Site (http://www.suvoda.com/terms-of-use), including to protect the rights, property, or safety of Suvoda, its users, or any other person, or the copyright-protected content of the Services.
  • To investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person, as well as regarding situations that involve abuse of the Services infrastructure or the Internet in general.
  • As required by law or regulation, or as requested by government authorities, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands, or to comply with requirements of mandatory applicable law.
  • To analyze how you use the Site, including how you interact with applications, advertising, products, and services that are made available, linked to, or offered through the Site.
  • To consider and implement mergers, acquisitions, reorganizations, consolidations, changes of control or sale of all or a portion of our assets, bankruptcies or liquidations and other transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

Sensitive Personal Information. We do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by the CCPA. Accordingly, we only use and disclose sensitive personal information as reasonably necessary and proportionate: (i) to perform our Services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our Services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

Aggregate and Deidentified Personal Information

We may use and disclose aggregate and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Where we use, disclose, or otherwise process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to the CCPA.

California Residents’ Rights. Under the CCPA, California residents have the following rights (subject to certain limitations):

  • To opt out of sales and sharing. The right to opt-out of our sale and sharing of their personal information.
  • To limit certain uses and disclosures of sensitive personal information. We only use and disclose sensitive personal information for purposes authorized under the CCPA; thus, this right is not available to California residents.
  • The right to the deletion of their personal information that we have collected, subject to certain exceptions.
  • To know/access. The right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
  • The right to correct inaccurate personal information that we maintain about them.
  • Non-discrimination. The right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

 

Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below:

  • Right to Know, Delete, and Correct. California residents may submit CCPA requests to access/know, delete, and correct their personal information by using our webform (available here), or by calling (888) 225-0665 .

When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial.

You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization and we may also require the relevant California resident to directly verify the identity and the authority of the authorized agent.

  • Right to Opt Out of Sales and Sharing. To exercise your right to opt out of the “sale” or “sharing” of your personal information, you may do so via our cookie preference manager. We will apply your opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. You may also click the “Do Not Sell or Share My Personal Information” link in the footer of our Site.

In addition, if we detect that your browser or device is transmitting an opt out preference signal, such as the GPC signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your personal information. If you come to our Site or use our Services from a different device or from a different browser on the same device, you will need to opt out, or use an opt out preference signal, for that browser and/or device as well. More information about GPC is available at: globalprivacycontrol.org.

 

California Shine the Light Rights. California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) permits California residents who provide us certain personal information to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing purposes. To make a California Shine the Light request, please call (888) 225-0665 or email us at privacy@suvoda.com. Requests may be made once per year.

Questions. If you have questions about this Policy, please contact us as described in Section 12 above.

 

Last updated: 17-Sept-2025