Privacy Policy

1. We are committed to protecting the data you share with us. This Privacy Policy explains how information about you is collected, used and disclosed by Suplyhotspot LLC (together with its affiliates, “Suplyhotspot” “we”, “us”, and “our”). We respect your concerns about privacy and personal data protection and value our relationship with you. This Privacy Policy applies to information we collect when you use our website, mobile applications, and any of our products or services (collectively, the “Services”), whether accessed via computer, mobile device, or other device (collectively, “Device”).

   We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

   By affirmatively accepting these terms, or otherwise using the Services, you hereby agree with and consent to the collection and processing of your personal information as described in this Privacy Policy.

   As further described herein, your personal information may be collected, processed and stored by Suplyhotspot or its service providers in the United States and other countries where such servers reside. You hereby agree with and consent to the transfer of your personal information to the United States and other countries where we and our service providers operate.

   You may have a legal right to withdraw your consent to Suplyhotspot’s collection and processing of your information, or to the transfer of your personal information across borders. To request to withdraw your consent, please contact us as set forth below.

   This Privacy Policy does not apply to, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through the Services or to which the Services contain a link. The availability of, or inclusion of a link to, any third-party site or property on the Services does not imply endorsement of it by us or by our affiliates. You should read the privacy policy for each site, web property, and application that you visit or use.

   Collection Of Information

   Information You Provide Us

   We will collect any and all information you provide to us, including the types of information described below.

   • We will collect any and all personal information that you choose to provide to us. For example, we collect personal and related information when you communicate with us or submit a contact form to us. If you register for an account with the Services, or contact us via the Services, we require that you provide certain personal information that could reasonably be used to contact you or to identify you personally which may include, but not be limited to, your name, email address, postal address, phone number, business name, type, address, and other contact information, business service area, job title, and any other information you choose to provide. If you choose to use certain services offered via the Services, you may choose to provide certain information necessary to provide such services that Suplyhotspot will store. To be eligible for listing on our platform as a supplier or buyer, and, as a supplier, if you choose to submit products for listing on our platform, you will be required to provide information relating to your company and the applicable products, which information will be subject to Suplyhotspot’s review and approval. By way of example, we will use your personal information to respond to your inquiries and to otherwise communicate with you.
   • If you choose to request product samples or purchase products using the Services, you will need to provide your shipping address and any other information required by our platform to process that transaction. We will maintain a record of the purchases that you make and the sales that you transact using the Services.
   • If you choose to make a payment on or using the Services (e.g., to remit subscription fees to us or to pay for products purchased through the Services), Suplyhotspot may ask you to provide your name, mailing address, telephone number and email address, as well as certain financial information (e.g., credit or debit card number) for purposes of processing that payment. Such information is sent directly to our third-party payment processor for processing. To make a payment, you will need to provide the billing name, billing address, and card type, number, expiration date, and security code. Suplyhotspot does not directly access, handle, or store your credit or debit card information, except that Suplyhotspot may store the last four digits of your credit or debit card number to assist our payment processor with recurring payments. Our payment processor, Stripe, may use your payment-related information in accordance with the Stripe Privacy Policy
   • In addition to the types of information described above and below in this section, information collected from registered buyers on the Platform may include, for example, instructions for receiving product samples; product categories of interest; information on the type of buyer business; store count; and company website, description, geographical reach.
   • In addition to the types of information described above and below in this section, information collected from registered suppliers on the Platform may include, for example, departments that best describe your industry (e.g., ”Apparel & Accessories”, “Beauty”, “Electronics & Entertainment”), company locations, brand information (e.g., year founded, revenue, related media, social media pages), product information (e.g., names, categories, regulatory approval information, descriptions, images, SKU numbers and other identifiers, product cost, MSRP, pricing information, and packaging and dimensions), distribution information (e.g., location of manufacture, availability dates and locations, product storage requirements), and marketing information (e.g., promotional budget, product videos).
   • If you choose to create, build, post, upload, display, publish, distribute, transmit, broadcast, or otherwise make available on or submit or provide through our platform (collectively, “provide”) any messages, avatars, text, illustrations, files, images, graphics, photos, comments, responses, videos, information, content, ratings, reviews, data, questions, suggestions, or other information or materials, we will collect all such user-generated content. You are responsible for any and all such user-generated content. You understand and acknowledge that certain features of our platform may allow or require user-generated content you provide to be made available to other platform users and that, accordingly, those other users may be able to access and use that user-generated content. User-generated content that you provide is transmitted at your own risk. We cannot guarantee that user-generated content will not be viewed by unauthorized persons. You understand that, even after removal, user-generated content you have provided may remain viewable to and may have been copied or stored by other users of our platform. For more information on user-generated content and how it’s used and disclosed, please review our Terms of Service
   • You may choose to receive certain communications from Suplyhotspot via your email address upon interaction with the Services. From time to time Suplyhotspot may include surveys, information requests, or other features on the Services which ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by Suplyhotspot to allow you to participate in the particular feature being offered. Suplyhotspot may also retain any information you provide in order to send you information about Suplyhotspot products and services that may be of interest to you. We may use one or more service providers to administer these messages. You have the right to withdraw your consent at any time by clicking the “un-subscribe” link in our emails to you or by emailing us at privacy@suplyhotspot.com.
   • We may combine the personal and other information you submit or provide through the Services with other information we have collected from you, whether on or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources, and other third parties.

   Other Information We Collect When You Use the Service

   When you access or use our Services, we passively collect a variety of types of information, including:

   • Platform Activity: We will collect information on how the Platform and Platform accounts are used, for example, the features users choose to use, user search parameters, data reflecting the purchase and sale of products using the Platform, and other product, transactional, and marketplace data.
   • Technical and Log Information: When you visit our Services, the system automatically records data and information about the user’s computer each time the website is accessed. Such technical information includes, without limitation, the type of browser you use, access times, pages viewed, your IP address (which may provide approximate geographical information) and the page you visited before navigating to our Services. By way of example, we collect and use this technical information for the purposes of (network) security (for example, to ward off cyberattacks), to better understand our users’ needs, to continuously improve our website and to enable users to access the website from their computers.
   • Device Information: We collect information about the Device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
   • Location Information: In addition to the approximate geographic location information collected as discussed above, we may, with your consent, access more specific location information to enhance the user experience and increase the usefulness of the Services. This includes both geographical location information that you input using the Services (e.g., when you enter a shipping address) and, as applicable, geographical location information collected by device-based location services (including GPS data). You may choose to allow us to access your location by granting the Services access to your location when prompted or through your device’s location services settings. Company also uses the Google Maps API(s). Pursuant to the Google Maps APIs Terms of Service, use of this location feature is also subject to Google's Privacy Policy. For information on how Google categorizes location information, please visit Types of location data used by Google. Both the Google Terms of Services and Google's Privacy Policy are incorporated into this Privacy Policy by this reference.
   • Analytics, advertising, and retargeting services information as described below. By way of example, if you are a registered buyer on the Platform, we will collect data about which brands and products you have viewed on the Platform. We use this information, for example, to show registered supplier users information about interest that is shown in suppliers’ brands and products.
   • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see "Your Choices" below and our Cookie Notice & Policy.
   • How We Respond to Do-Not-Track Signals: Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information, including for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or Device to delete and disable cookies and other tracking and recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.

   Information We Collect From Other Sources

   We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to, our affiliates, identity verification services, and credit bureaus.

   Use Of Information

   We may use information about you for various purposes, including to:

   • Provide, maintain and improve our Services;
   • Provide and deliver, or facilitate the provision or delivery of, the products and services you request or order, process transactions and send you related information, including confirmations and invoices;
   • Communicate with you about products and services;
   • Respond to your inquiries;
   • Send you important information regarding our relationship with you or regarding the Services, changes to our terms, conditions, and policies and/or other administrative information;
   • Further our business purposes, such as marketing new products and services, data analysis, audits, developing new products or services, operating or enhancing our Services, improving our products and services, identifying Services usage trends, providing products and services, maintaining customer relationships, improving the quality, safety, and security of our products and services, administering your account(s), troubleshooting, supporting electronic signature, customizing and improving communication content, evaluating product performance, providing customer support and product support, and determining the effectiveness of our Services;
   • We may anonymize and aggregate personal information and user-generated content, as well as aggregate other collected information, and use that aggregate data in any manner for our business purposes, in each case to the extent permitted by applicable law. Such purposes include, without limitation, to understand and analyze Platform usage patterns and the needs of suppliers and retailers, to improve and enrich our products and services, the monetization of such aggregate data, and to license, sell, and otherwise distribute aggregate data to third parties. We may provide aggregate information to our affiliates and to suppliers, retailers, buyers, and other third parties (including users of our Services) for these purposes; and
   • Carry out any other purpose for which the information was collected, subject to applicable law.

   Sharing Of Information

   We may share information about you as follows or as otherwise described in this Privacy Policy:

   • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including but not limited to service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services;
   • With other users of the Services as you may request, solely as necessary to provide such Services. For example, to facilitate products orders or, as a supplier on our online platform, we may share business and personal contact information with verified buyers so that they may more easily contact you;
   • With our affiliated entities for the purpose of direct marketing of related services and sending of invitations to sessions that we reasonably believe may be of interest to you, subject to applicable law;
   • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
   • With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner or with a particular party and you provide such information.
   • In addition, we use and disclose personal information collected through the Services as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or those of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
   • With your consent, we may use and share your personal information and other collected information in ways not specifically described in this Privacy Policy.

   We also use and disclose information that is not in personally identifiable form (such as anonymized, aggregated, masked or de-identified information) for any purpose, including to understand platform users’ needs and usage patterns, to determine what kinds of products and services we can provide, and to improve and enrich our products and services.

   Social Sharing Features

   The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. These features may require us to implement cookies, plug-ins, and application protocol interfaces (APIs) provided by those social media platforms to facilitate those communications and features. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the respective social media platforms. We cannot control any policies or terms of such third party platform. As a result, we cannot be responsible for any use or disclosure of your information or content by third-party platforms, which you use at your own risk.

   Single Sign-On

   You may have the option of logging into and/or linking your online Suplyhotspot account by providing your log-in information for certain third-party services. If you choose to use these single sign-on features, we may access, handle, and store content and information that you have provided through or that is tied to the applicable third-party service account. These features may require us to implement cookies, plug-ins, and application protocol interfaces (APIs) provided by the applicable third parties.

   Analytics, Advertising, And Retargeting Services

   We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. As further discussed below, this information may be used by Suplyhotspot and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.

   The Services use third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Services, including when you visit the Services, URLs of the websites that you visit prior to visiting the Services and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content.

   For more information on how Google uses this data, visit Google's Privacy Policy and Google’s page on How Google uses data when you use our partners' sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent Company from using other analytics tools and will not prevent data from being sent to the Services themselves or to Google. For more information about how Google Analytics uses cookies to measure user interactions on websites, visit Google Analytics Cookie Usage on Websites.

   Additionally, we have enabled and implemented the following Google Analytics Advertising Features: Remarketing with Analytics, Demographics and Interest reporting, Campaign Manager integration, Display & Video 360 integration, Google Display Network (GDN) Impression Reporting, and Segments. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Services. Demographics and Interest reporting uses a third-party cookie to collect information about Services traffic by tracking users across websites and across time, which generates a report for us to better understand users of our Services. Campaign Manager integration allow us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video 360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video 360. Google Display Network (“GDN”) Impression Reporting allows us to measure the impact of unclicked GDN Display ad impressions on website behavior and conversions. Segments allows us to isolate and analyze subsets of Services users by sorting our Google Analytics data.

   To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Services.

   We encourage you to review FullStory’s Privacy Policy. To opt out of FullStory, click here.

   From time to time the Services may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms. These services collect information about your visits to and interactions with the Services and other websites and will use that information to target advertisements for goods and services. The information collected may be associated with your personal information. These targeted advertisements may appear on the Services or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Services and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.

   For more information about Internet-based ads and online behavioral advertising, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads or third-party ads from time to time.

   Security

   Suplyhotspot takes reasonable measures designed to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with this Privacy Policy.

   Access by Children

   We do not knowingly collect information from individuals under the age of 13. The Services are not directed to individuals under the age of 13 and we request that these individuals not provide any information through the Services.

   Your Choices

   Account Information

   You may update, correct or delete information about you at any time by logging into your online account or emailing us at support@suplyhotspot.com. If you wish to delete or deactivate your account, please email us at support@suplyhotspot.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you or provided by you for a certain period of time.

   Cookies

   Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information about cookies and how to disable them, please see our Cookie Notice & Policy.

   Marketing and Promotional Communications

   You may opt out of receiving promotional emails from Suplyhotspot by following the instructions in those emails or by emailing support@suplyhotspot.com and requesting to be removed from our mailing list. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

   We will respond to you within a reasonable time of your request.

   International Transfers of Information

   By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to countries other than the country of which you are a resident. Those countries may have data protection laws that are different from those of your country and, in some cases, may not be as protective. Your personal information may be stored and processed in any country where we have facilities or service providers. Suplyhotspot is based in the United States but uses service providers operating around the world.

   While this Privacy Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Suplyhotspot (“Local Laws”) may require standards which are stricter than this Privacy Policy and, in such event, Suplyhotspot will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions.

   Irrespective of the country to which your personal information is transferred or in which it is processed, we take appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy and all applicable law.

   EU Data Subjects

   In the European Economic Area and Switzerland (“EU”), “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you. The legal basis’ for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to Suplyhotspot’s use or disclosure of your Personal Data will mean that you cannot take advantage of certain Suplyhotspot products or services.

   As further addressed above, we may transfer your Personal Data outside the EU to the United States or any country that Suplyhotspot or its service providers may have operations. Such countries may not have the same data protection laws as the EU. Any transfer of your Personal Data will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation (“GDPR”)) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the such safeguards please contact us.

   Under the GDPR you have a number of important rights free of charge. In summary, those include rights to:

   • Fair processing of information and transparency over how we use your use personal information
   • Access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address
   • Require us to correct any mistakes in your information which we hold
   • Require the erasure of personal information concerning you in certain situations
   • Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
   • Object at any time to processing of personal information concerning you for direct marketing
   • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
   • Object in certain other situations to our continued processing of your personal information
   • Otherwise restrict our processing of your personal information in certain circumstances

   For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the GDPR (or other relevant guidance).

   If you would like to exercise any of those rights, please:

   Email, call, or write to us with the following:

   • Enough information to identify you
   • Proof of your identity and address
   • The information to which your request relates

   How to Complain

   The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the EU state where you work, normally live, or where any alleged infringement of data protection laws occurred.

   Third-Party Websites

   The Services may link to, or be linked to, websites, or services not maintained or controlled by Suplyhotspot. Suplyhotspot is not responsible for the privacy policies or practices of any third parties or any third-party websites, applications, or services. This Privacy Policy does not apply to any third-party websites, applications, or services or to any personal or other information that you may provide to third parties. You should read the privacy policy for each website, application, and service that you visit or use.

   Compliance

   Suplyhotspot will use a self-assessment approach to verify compliance with this Privacy Policy and periodically verify that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

   If you believe that your personal information has been processed or disclosed in violation of this Privacy Policy, Suplyhotspot encourages you to raise any concerns using the contact information provided in this Privacy Policy. Suplyhotspot will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

   Contact Us

   If you have questions or requests regarding this Privacy Policy, or if you would like to exercise your rights, please contact us by email to privacy@suplyhotspot.com

   You may also contact our Data Protection Officer as follows: dpo@suplyhotspot.com.