PRIVACY
EEA and UK Privacy Supplement
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1. Controller and contact details
Supercent Inc. (“Supercent”) is the controller of personal data processed through the Services unless a Service-specific notice states otherwise. You can contact us or exercise your rights at help@supercent.io or through the privacy request mechanism in the relevant Service.
Data Protection Officer (DPO) You may contact our Data Protection Officer regarding the processing of your personal data and the exercise of your rights at help@supercent.io.
2. Legal bases for processing
We process personal data only when we have a legal basis. The applicable basis depends on the purpose, context and Service feature. Information identified as necessary for account access or a requested feature is required to provide that function; without it, we may be unable to provide the function. Transaction or tax information may also be required by law. Optional information is not required to use unrelated core features.
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Processing activity | Primary legal bases | Explanation |
|---|---|---|
Account creation, authentication and core Service features | Performance of a contract; steps requested before a contract | Needed to create and manage an account, save progress, deliver content, process uploads and provide requested AI, chat or community features. |
Purchases, subscriptions, rewards and creator payments | Performance of a contract; legal obligation | Needed to process transactions, administer entitlements, calculate payments, maintain accounting records and comply with tax and consumer law. |
Content recommendations and product personalization | Legitimate interests; consent where required | We have an interest in making the Services useful and relevant. Consent is used where required for tracking or more intrusive personalization. |
Contextual advertising and basic measurement | Legitimate interests; consent where required for device access or tracking | Supports contextual ad delivery and basic measurement, subject to applicable device-access consent and safeguards. |
Personalized advertising, non-essential cookies and cross-service tracking | Consent | We request consent where ePrivacy or data protection law requires it. Consent may be withdrawn through the applicable privacy controls or help@supercent.io. |
UGC hosting, moderation and rights claims | Performance of a contract; legitimate interests; legal obligation | Needed to publish requested content, keep the community safe, investigate reports, protect rights and comply with removal obligations. |
AI chat and content moderation | Performance of a contract; consent for optional or sensitive uses; legitimate interests for safety | Process chat messages and context to provide responses, moderate content and prevent misuse. |
Security, fraud prevention and enforcement | Legitimate interests; legal obligation | We and others have an interest in preventing account takeover, fraud, invalid traffic, illegal content and misuse. |
Analytics, troubleshooting and improvement | Legitimate interests; consent where required for non-essential technologies | Helps us understand performance, fix errors and improve products with safeguards such as aggregation and access limits. |
Marketing communications | Consent, or legitimate interests where permitted | We provide required notices and send optional marketing based on consent and local rules. |
Legal claims, audits and regulatory responses | Legal obligation; legitimate interests | Needed to comply with law and establish, exercise or defend legal claims. |
3. Legitimate interests
Our legitimate interests are Service operation and improvement, security, fraud prevention, moderation, advertising measurement, program administration and the establishment or defence of legal claims. You may object to processing based on legitimate interests.
4. AI features and automated decision-making
AI chat processing and recipient information are described in the Global Privacy Policy and provider Schedule.
We do not currently use solely automated decision-making that produces legal or similarly significant effects within Article 22 GDPR.
5. Cookies, advertising and consent
Where required, we obtain consent for non-essential cookies, analytics, personalized advertising and cross-service tracking. You may withdraw consent through the applicable privacy control or help@supercent.io, without affecting earlier lawful processing.
6. Recipients and processors
We disclose personal data to processors and other recipients described in the Global Privacy Policy, including providers of hosting, analytics, AI functionality, content moderation, customer support, advertising, payments, creator payouts, identity verification and security. The Service Providers, Third-Party Disclosures and International Transfers provides current categories and transfer information.
7. International transfers
Supercent is established in the Republic of Korea. Transfers of personal data from the EEA or United Kingdom directly to Korea may rely on the applicable adequacy decisions recognizing Korea’s level of protection, where their scope and conditions are met.
For transfers to a country or recipient not covered by an adequacy decision, we use an appropriate safeguard such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, together with transfer assessments and supplementary contractual, organizational or technical measures where needed. You may request information about the applicable safeguard by contacting us.
8. Retention
Retention periods and criteria are described in the Global Privacy Policy and provider Schedule. Erasure is subject to the exceptions in applicable law.
9. Your data protection rights
Subject to applicable conditions and exceptions, you may have the following rights.
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Right | What it means |
|---|---|
Access | Obtain confirmation of processing and a copy of your personal data, together with required information about the processing. |
Rectification | Correct inaccurate personal data and complete incomplete information. |
Erasure | Request deletion where the data is no longer needed, consent is withdrawn, an objection succeeds or processing is unlawful. |
Restriction | Request that we limit processing in circumstances specified by law. |
Data portability | Receive certain data you provided in a structured, commonly used and machine-readable format and, where feasible, transmit it to another controller. |
Object | Object to processing based on legitimate interests, including related profiling, and object at any time to direct marketing. |
Withdraw consent | Withdraw consent at any time through available settings or by contacting us. |
Automated decisions | Obtain applicable safeguards regarding solely automated decisions with legal or similarly significant effects. |
Complaint | Lodge a complaint with the supervisory authority in your habitual residence, place of work or place of the alleged infringement. |
Submit a rights request through available Service controls or help@supercent.io. We may request information necessary to verify your identity. We respond without undue delay and within one month; where legally permitted, this may be extended by up to two further months, with reasons provided within the first month.
10. Children and teenagers
Where consent is the legal basis for an online service offered directly to a child, we apply the relevant national age threshold and obtain parental authorization where required.
11. Complaints and contact
You may complain to the supervisory authority in your place of residence, work or the alleged infringement. EEA authority details are available through the European Data Protection Board; the UK authority is the Information Commissioner’s Office. You may also contact help@supercent.io.