Privacy Policy

1. Introduction and Scope

Effective and Last Updated: July 25, 2026

Welcome to Superpage Systems Inc. ("Superpage," "we," "our," or "us"). This Privacy Policy explains how we collect, use, process, and disclose your information.

Role Distinctions: Superpage acts as a data controller (or "business") for data directly related to our website visitors, account creation, billing, and direct-relationship data. Conversely, Superpage acts as a data processor (or "service provider") for customer-controlled data submitted to our platform, including contact lists, leads, campaign information, CRM records, form submissions, bookings, email, SMS, payment-related data, and automation data. If you are an end user interacting with a campaign run by a Superpage customer, please direct any privacy rights requests to the relevant customer, as they control your data.

2. Categories of Information Collected

We collect information that identifies, relates to, describes, or could reasonably be linked with you or your device. The categories expressly include:

• Identity and Contact Data: Name, email address, phone number, postal and billing details, account credentials, and organization/profile details.
• Customer and Campaign Content: Uploaded assets/content, AI prompts, AI inputs/outputs, campaign, ad, CRM, form, booking, and contact data, as well as imported data.
• Financial Information: Payment transaction metadata (note that full payment card data is handled directly by third-party payment providers).
• Communications Data: Correspondence with our team, and communications and consent records (including email and SMS interactions).
• Technical and Usage Data: Device data, network logs, cookie data, usage metrics, approximate location, and integration tokens necessary for external service connections.

3. Sources of Information

We collect personal information from various sources: directly from you when you provide it (e.g., registering an account or communicating with us), automatically via your devices when interacting with our platform and website, and from third parties including integrations, external service providers, and our customers.

4. Business Purposes for Processing

We use the collected information for detailed business and commercial purposes, including:

• Providing, maintaining, and personalizing the Superpage platform and services.
• Processing transactions, billing, and executing customer-directed campaigns.
• Analyzing and optimizing platform performance, marketing activities, and technical functionality.
• Communicating administrative notices, updates, and promotional content.
• Detecting, preventing, and responding to security incidents, fraud, or technical issues.
• Complying with legal obligations and enforcing our legal terms.

5. EEA/UK Legal Bases

Where the General Data Protection Regulation (GDPR) or UK GDPR applies, we rely on the following legal bases to process personal data: the performance of a contract (e.g., providing the requested services), our legitimate business interests (e.g., improving security and platform functionality), compliance with a legal obligation, and consent where legally required. We do not rely on a blanket consent claim for all processing activities.

6. AI Processing and Provider Use

Superpage utilizes third-party AI providers to deliver core platform functionalities. This processing may involve human review where operationally necessary and explicitly authorized. Output limitations are enforced based on provider constraints and safety guidelines. We state conservatively that Superpage does not use Customer Content to train generalized AI models without the customer’s explicit authorization. Our AI providers process data strictly under applicable service terms and our instructions.

7. Disclosures to Third Parties

We may disclose your information to the following categories of recipients:

• Service Providers and Subprocessors: Including hosting/infrastructure, AI, analytics, communications, CRM, advertising, scheduling, payment processing, security, support, and professional-service providers.
• Third-Party Integrations: Where you enable external integrations, data is shared subject to those providers' independent terms.
• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.
• Legal and Safety Disclosures: As necessary to comply with the law, respond to valid legal requests, enforce our terms, or protect our rights, users, or the public.

8. International Data Transfers

Superpage operates primarily in the United States. Where personal data is transferred internationally from the EEA, the UK, or Switzerland, we utilize appropriate safeguards such as Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, applicable adequacy decisions, or other legally recognized equivalent safeguards where applicable.

9. Data Retention

We retain personal data based on criteria tailored to the purpose of collection, legal requirements, active disputes, security imperatives, and routine backup schedules. Once data is no longer necessary for these purposes, or upon validated account deletion requests, it is securely deleted, anonymized, or scheduled for removal in our backups in accordance with applicable handling procedures.

10. Security Measures

We implement reasonable administrative, technical, and organizational security measures to safeguard your personal data. While we strive to protect your information against unauthorized access, destruction, or alteration, no electronic transmission or storage system is entirely secure, and we cannot make absolute guarantees regarding the security of your information.

11. Cookies and Similar Technologies

We utilize cookies, pixels, and local storage to operate essential platform features and, when permitted, deploy analytics and advertising technologies. You have consent controls where legally required and may exercise browser or platform-level choices. You can modify your preferences using our site's cookie choice mechanisms or browser settings at any time.

12. Marketing Email and SMS Communications

We may send transactional and service-related messages as part of our core platform operation. For marketing emails and optional SMS text messages, we collect explicit consent where required. You may opt out of marketing emails at any time. For SMS communications, we distinguish two separate categories: informational/event messages about requested demos or registered events (confirmations, reminders, schedule changes, access details, and related service notices), and recurring marketing messages about future events, products, services, discounts, and special offers. Message frequency varies, and standard message and data rates may apply. Reply STOP to unsubscribe, and reply HELP for assistance. Carriers are not liable for delayed or undelivered messages. We do not sell or share mobile phone numbers, SMS opt-in data, or SMS consent with third parties or affiliates for their marketing or promotional purposes. We may disclose this information only to service providers that help us deliver messaging services, subject to contractual restrictions, or when required by law.

13. EEA and UK Privacy Rights

Individuals in the EEA and the UK have specific rights regarding their personal data. These include the rights to access, correct, delete (erasure), restrict processing, object to processing, and request data portability. You also have the right to withdraw your consent where applicable and the right to lodge a complaint with your local supervisory authority.

14. US State Privacy Rights

Residents of comprehensive US state privacy law jurisdictions (e.g., California, Virginia, Colorado, Connecticut, Utah) have specific rights—subject to jurisdictional exceptions. These include the right to know/access, correct, delete, and port your personal information, as well as the right to appeal denied requests and the right to non-discrimination for exercising your rights. Authorized agents may submit requests on your behalf, subject to identity verification.

Sales, Sharing, and Targeted Advertising: Superpage does not sell personal information for money. However, certain disclosures to advertising and analytics providers may be deemed a "sale," "sharing," or "targeted advertising" under various state laws when enabled. You have the right to opt out of these activities, as well as the right to opt out of qualifying profiling. You may exercise these opt-outs through our site's cookie choices, legally recognized Global Privacy Control (GPC) signals, or by emailing hello@superpage.io. You also have the right to limit the use of sensitive personal information where applicable.

15. Sensitive Information

To the extent we collect sensitive personal information, it is used strictly for permitted, operationally necessary purposes. We do not use or disclose sensitive information to infer characteristics about you beyond these limited, permitted operational intents.

16. Automated Decision-Making and Profiling

Where applicable, you have the right to opt out of automated decision-making and profiling that produces legal or similarly significant effects. Please note that our customers retain ultimate control over the execution of their campaigns; users and individuals should not rely solely on Superpage's AI processing for high-impact decisions affecting individual rights or well-being.

17. Children's Privacy

Our platform is designed for general business audiences. We do not knowingly collect personal information from individuals under the age of 16. If we learn that we have inadvertently obtained personal information from a child under 16, we will take prompt steps to delete that information.

18. Do Not Track and Global Privacy Control

While some browsers feature a "Do Not Track" signal, these are not uniformly recognized across the industry, and our systems may not currently respond to them. However, we do honor legally required Global Privacy Control (GPC) signals sent from your browser or extension.

19. Changes to This Policy

We may update this Privacy Policy from time to time to reflect modifications in our practices or applicable laws. If we make material changes, we will notify you by updating the "Last Updated" date at the top of this document or by sending a direct communication via email.