Last updated on 29th of December 2017.
a) What information we collect and why we collect it;
b) How the information is (may be) collected;
c) How we use that information and for what purpose;
Suplo collects all information about You to provide better services to our users. With information collected we try to understand which ads You’ll find most useful, which additional services You may need, etc.
Suplo collects (may collect) information in the following ways:
when You submit any information to Suplo platform relating to any of our Services;
when You interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;
when You use some of our services, for example, websites and apps including establishing any online accounts with us;
when You purchase or obtain third party services through us;
when You request that we contact You, be included in an email or other mailing list;
when You respond to our promotions, initiatives or to any request for additional Personal Data;
when You are contacted by, and respond to, our marketing representatives and customer service officers;
when we receive references from business partners and third parties, for example, where You have been referred by them;
when we seek information from third parties about You in connection with the Services You have applied for; and
when You submit Your Personal Data to us for any other reasons.
When You browse Suplo platform without subscribing to it, You generally do so anonymously but please see the section below on cookies. We do not at our platform automatically collect Personal Data unless You provide such information or login with Your account credentials.
If You provide us with any Personal Data relating to a third party (e.g. information of Your spouse, children, parents, and/or employees, consultants, partners, representatives etc.), by submitting such information to us, You represent to us that You have obtained the consent of the third party (-ies) to provide us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on Your part to do so may result in our inability to provide You with the Suplo platform features or Services You have requested.
Notwithstanding of the said above Suplo may gather other information about You in these additional ways:
a) By gathering device-specific information
We may collect device-specific information (such as Your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). Suplo may associate Your device identifiers or phone number with Your Suplo account on the Suplo platform or Your other details.
b) By gathering log information
When You use our services or view content provided by Suplo, we may automatically collect and store certain information in server logs. This includes details of how You used our service, such as Your search queries, telephony log information like Your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls, internet protocol addresses, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of Your request and referral URL, cookies that may uniquely identify Your browser, software, hardware or Your actions.
c) By gathering location information
When You use Suplo services, we may collect and process information about Your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide Suplo with information on nearby devices, Wi-Fi access points and cell towers.
d) By gathering unique application numbers
Certain services include a unique application number. This number and information about Your installation (for example, the operating system type and application version number) may be sent to Suplo when You install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
e) By using cookies and similar technologies
We and our partners use various technologies to collect and store information when You visit the Suplo platform or using any Suplo Service. This may include using cookies or similar technologies to identify Your browser or device. We also use these technologies to collect and store information when You interact with Services we offer to our partners or our partners offer to You, such as advertising services or Suplo features that may appear on other sites.
Information we collect ourselves may be combined with information we obtain about You from our partners or other sources. When information is associated with Your Suplo account, we treat it as Your Personal Data.
Personal Data refers to any data, whether true or not, about You or an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data You may provide to us include (depending on the nature of Your interaction with us) Your name, surname, personal code, social security code, account number, credit card details, passport or other identification numbers, telephone number(s), mailing address, email address, IP address, network data and any other information relating to any individuals which You have provided us in any forms You may have submitted to us, or via other forms of interaction with You.
Purposes for the Personal Data collection. Use and Disclosure of Your Personal Data
Generally, Suplo collects, uses and discloses Your Personal Data (including Sensitive Personal Data) for the following purposes:
responding to Your queries and requests;
managing the administrative and business operations of Suplo platform and Services and complying with internal policies and procedures;
facilitating Your business transactions;
resolving complaints and handling requests and enquiries;
preventing, detecting and investigating crime and analyzing and managing commercial risks;
providing media announcements and responses;
monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
legal purposes (including but not limited to obtaining legal advice and dispute resolution);
conducting investigations relating to disputes, billing, suspected illegal activities or fraud;
meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Suplo (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
opening or continuation of accounts and establishing or providing You with the Suplo services You subscribe to (including but not limited to service activation, service operations, service delivery and order processing);
facilitating the continuation or termination of Your subscription to Suplo platform and Services (including but not limited to administering subscription arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);
facilitating the daily operation of the Suplo platform and Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
facilitating third party services if purchased, obtained, administered or processed through us;
processing of payment instructions, direct debit facilities and/or credit facilities requested by You;
enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
administering and processing any insurance claims and payments arising under the respective policies;
credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
generating internal reports (including but not limited to annual, operational and management reports);
processing referral payments and commission fees to our external partners;
administering fee adjustments, refunds and waivers;
notifying You of Your entitlements under loyalty and reward programmes with Suplo;
analysing Your use of the the Suplo platform and Services so as to help us improve, review, develop and efficiently manage the platform and Services offered to You; and
purposes which are reasonably related to the aforesaid.
Furthermore, where permitted Suplo may also collect, use and disclose Your Personal Data for the following:
marketing collaborations and co-branding.
analytics and tracking, including facilitating the sale of analytical data;
conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to Suplo and its partners, and to improve our service delivery and Your customer experience at our touchpoints;
providing additional Services and benefits to You;
matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Suplo Services;
administering contests, competitions and marketing campaigns, and personalising Your experience;
communicating to You advertisements involving details of Suplo and its Services, special offers and rewards (including but not limited to upselling, cross selling and telemarketing);
organising promotional events and corporate social responsibility projects; and
purposes which are reasonably related to the aforesaid.
Your Personal Data may be disclosed for Suplo purposes to the vendors or other third party service providers in connection with promotions and services offered by Suplo.
If You have provided Your telephone number(s) and have indicated that You consent to receiving marketing or promotional information via Your telephone number(s), then from time to time, Suplo may contact You using such telephone number(s) (including via voice calls, text, fax or other means) with information about Suplo platform features and Services.
You have a choice to withdraw Your consent for receiving marketing or promotional materials/communication. You may contact Suplo using the contact details found below.
Please be aware that once we receive confirmation that You wish to withdraw Your consent for marketing or promotional materials/communication, it may take up to 30 working days for Your withdrawal to be reflected in our systems. Therefore, You may still receive marketing or promotional materials/communication during this period of time. Please note that even if You withdraw Your consent for the receipt of marketing or promotional materials, we may still contact You for other purposes in relation to the Suplo Services.
Disclosure of Personal Data
Suplo will take reasonable steps to protect Your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, Your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities:
Suplo related corporations and employees to provide content, products and services to You, address Your questions and requests in relation to Your customer accounts, subscription and billing arrangements with us as well as our products and services, to activate, deactivate, install, maintain and operate our systems and/or services;
companies providing services relating to insurance and consultancy to Suplo;
agents, contractors or third party service providers who provide operational services to Suplo, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Suplo;
vendors or third party service providers in connection with marketing promotions and services offered by Suplo and its partners;
commercial shops and retailers in relation to providing rewards and benefits;
other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;
any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness;
external banks, credit card companies and their respective service providers;
our professional advisers such as auditors and lawyers;
relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
any other party to whom You authorise us to disclose Your Personal Data to.
A cookie is a small piece of information that is placed on Your computer when You visit certain websites.
You entitle Suplo using cookies on its websites for the following purposes:
enabling certain features and functions on our websites, eg. remembering Your user-id, favourite selections, browsing and other service preferences;
building up a profile of how You and other users use the Suplo platform;
improving the efficiency of the Suplo platform and Services;
administering services to You and to advertisers; and
establishing usage statistics
Most internet browsers provide You the option of turning off the processing of cookies (please see the “help” section of Your browser), but this may result in the loss of functionality, restrict Your use of the Suplo platform and/or delay or affect the way in which it operates.
Advertisements on the Suplo platform may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. Suplo does not control these third parties and their cookie policies and if You have questions about their cookie policies, please contact Suplo and we will try our best to assist by providing You information about these third party advertising agencies.
Suplo is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to the Suplo platform.
Withdrawal of Your Consent, Access and Correction of Your Personal Data
If You have any questions or feedback relating to Your Personal Data or Your Personal Data processing; if You would like to withdraw Your consent to any use of Your Personal Data as set out in this Data processing policy; or if You would like to obtain access and make corrections to Your Personal Data records, please contact Suplo via email: [email protected]
Please note that if Your Personal Data has been provided to us by a third party (e.g. a referrer), You should contact that organisation or individual to make such queries, complaints, and access and correction requests to Suplo on Your behalf.
If You withdraw Your consent to any or all use of Your Personal Data, depending on the nature of Your request, Suplo may not be in a position to continue to provide its Products and Services to You, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Suplo. You and / or Your employer may also occur in breach of Your contractual obligations or undertakings. Suplo legal rights and remedies in such event are expressly reserved.
Personal data governing Law
This Personal Data processing policy shall be governed in all respects by the laws of the Republic of Lithuania.