Privacy Policy

Last updated: 1st of Feb 2023

Introduction

Sunobi LLC, operating as Sunobi, is a company registered in California, USA.

Company Number: 202022010622

Email: support@sunobi.com

This Privacy Statement sets out how we will collect, use, disclose and protect your Personal Information where we act as the controller.

Please refer to the relevant customer’s Privacy Statement for how they collect, use, disclose and protect your Personal Information where we act as the processor.

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Definitions

This Privacy Statement uses the same definitions (and rules of interpretation) as those used in the Sunobi Terms of Service, found here.

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Changes to this statement

We may change this Privacy Statement from time to time in the future by uploading a revised version. The change will apply from the date that we upload the revised version.

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Information we collect

We collect information (including Personal Information about your name, job title, billing and mailing address, email address, phone number and credit card information, interactions you have with our app and Website. We collect this information from:

you, when you provide that Personal Information to us, through registration and use of Sunobi, through any contact with us (e.g. telephone call or email, web chat), or when you buy our products and services.

third parties, where you have authorised this, or where the information is publicly available.

your use of our service, including IP addresses, location information, browser information, and any other action you might take while using our service. We use this information to understand what content and features are effective and improve our services.

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How we use your Personal Information

We process Personal Information to:

verify your identity;
provide you with the Sunobi Services and otherwise carry out our obligations under the Terms;
respond to communications from you (including complaints) relating to the Sunobi Services;
identify you when you sign-in to your account and verify that your account is not being used by others;
bill you and to collect money that you owe us, including authorising and processing credit card transactions;
enforce compliance with our Terms; and
comply with laws and respond to lawful requests by public authorities.

and such processing is necessary for the performance of the contract between you and us.

We process Personal Information to:

improve our Sunobi Services;
analyse usage of the Sunobi Services, or carry out research and analysis, so we can improve the Sunobi Services;
protect and/or enforce our legal rights and interests, including defending any claim;
to comply with our obligations to our third-party service providers;
comply with our legal obligations, including any notification and reporting obligations and any access directions imposed on us by a Government agency or regulatory authority,

and such processing is necessary for the purposes of a legitimate interest pursued by us, and we have assessed that our interests are not overridden by the interests or fundamental rights and freedoms of the person to whom the Personal Information relates.

We process Personal Information to:

identify potential customers who may wish to use Sunobi Services;
market our products to you, including electronically by email;
tailor content or advertisements to you;
improve our website and Sunobi Services.

and such processing is completed with your consent. We may also use Personal Information collected for such other purposes that are compatible with the original purpose described above, or that you otherwise consented to from time to time.

You can unsubscribe from any communications from us by contacting us as directed in any such communications.

We may also use and disclose de-identified information (non-Personal Information) as set out in this Privacy Statement and as we otherwise determine, provided that there is only a low risk that any person could be re-identified from the information.

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Disclosing your Personal Information

We may disclose your Personal Information to:

other third parties for anonymised statistical information
a person who can require us to supply your Personal Information (e.g. a regulatory authority or lay enforcement agency)
any other person or entity authorised by you

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‍Overseas transfers

We utilise the services of entities in various countries (New Zealand, the European Union, the United States of America). Consequently, we may transfer Personal Information to parties located in these countries. Although we will endeavour to ensure that your Personal Information is treated securely and in accordance with this Privacy Statement as well as applicable data protection laws, you acknowledge that some of these countries may not have an equivalent level of data protection laws as those in United States of America.

You consent to the rights of access, processing and disclose on the basis specified above.

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How long we keep your Personal Information

We will keep your personal information:

until we no longer have a valid reason for keeping it
until you request us to stop using it
for as long as required by law e.g., we keep invoice information for 7 years to fulfil our tax obligations

When you delete your account, some information continues to be stored in backups.

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How we use cookies

A cookie is a piece of code that creates a file on your computer to track the pages that you view on our website. We use cookies for a variety of purposes as described above. Cookies allow browsing and other services offered through Sunobi, and need to be enabled. Read our Cookie and Analytics Policy to learn more about how we use cookies.

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Protecting your Personal Information

We take the protection of your personal information seriously and we will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.

Our data is always transmitted securely over HTTPS, passwords are kept encrypted and database and software is regularly checked for any potential security issues.

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Your rights

You have the right to access your readily retrievable Personal Information that we hold about you, and to ask for it to be corrected if you think it is wrong, or to be deleted.

If you are based in the European Union (including Switzerland and the United Kingdom) you also have the right, under the General Data Protection Regulation (EU) (GDPR), to:

in certain circumstances, have your Personal Information erased;
restrict the processing of your Personal Information;
move, copy or transfer your Personal Information easily for your own purposes across different services in a safe and secure way; and
object to processing where we rely on our legitimate interests as the lawful basis for processing.

Please note that in certain circumstances we may refuse to respond to a rights request where it we have the right to do so under the GDPR, for example, where a request is manifestly unfounded or excessive.

You can view more details around how we meet GDPR and any sub-processors on our GDPR page.

If you wish to exercise your rights under this Privacy Statement or any applicable data protection laws, you can do this by emailing our Privacy Officer at support@sunobi.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).
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If you want additional information to be deleted, please contact our Privacy team (support@sunobi.com).