Privacy Policy

This Privacy Notice (“Notice”) only applies when SuMeera Solutions Inc. (“SuMeera Solutions,” “us,” “we,” or “our”) is the Controller of personal data (example: SuMeera Solutions website visitors’ personal data and business-to-business contact data). SuMeera Solutions is a Processor, not a Controller, of personal data that we process on behalf of our Customers when they use SuMeera Solutions products and Services. For clarity, this means that this Notice does not apply to SuMeera Solutions products and Services. If you have questions related to how a SuMeera Solutions Customer utilizes your personal data, please contact them directly. We are not responsible for the privacy or data security practices of our Customers. This Notice also does not apply to personal data about current and former SuMeera Solutions employees, job candidates, or contractors and agents acting in similar roles.

Table of Contents:

Introduction
Personal Data We Collect and Disclose
How We Process Personal Data
Sources of Personal Data
Cookies and Tracking Technologies
Security and Retention
Children’s Privacy
External Links
Supplemental Terms for California Residents
Supplemental Information for the EEA, Switzerland, and the U.K.
Supplemental Information for Other Regions
Contact Information
English Version Controls

1. Introduction

Capitalized terms that we use but are not defined in the Notice (such as Site, Services, etc.) have the meaning provided in our Terms of Service - Subscription Agreement (“Agreement”). If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“U.K.”), please refer to Section 10 of this Notice for more information about which specific entity or entities act as a controller of your personal data.

When Does This Notice Apply? This Notice only applies to personal data that SuMeera Solutions handles as a Controller (meaning where SuMeera Solutions controls how and why your personal data is processed). This includes when you:

Visit or interact with the SuMeera Solutions.com website, our branded social media pages, and other Sites which we operate (collectively, our “Digital Properties”);
Register for or participate in our webinars, events, programs, marketing, and promotional activities;
Interact with us in person, such as when you visit our offices; and
Inquire about or engage in commercial transactions with us.

Changes: We may update this Notice from time to time. Please check back periodically for updates. If you do not agree with any changes we make, you should stop interacting with us. When required under applicable law, we will notify you of any changes to this Notice by posting an update on our Privacy Notice webpage or in another appropriate manner.

2. Personal Data We Collect and Disclose

SuMeera Solutions will honor data subject rights to the extent required by law. You may have the right to access, correct, update, and, in some cases, request deletion of your personal data (subject to exceptions). You may submit a request here.

SuMeera Solutions uses a limited number of third-party service providers to assist us in processing data for certain purposes. These third-party providers help support certain site features, perform database monitoring and other technical operations, assist with the transmission of data, and provide data storage services. These third parties may process or store personal data while providing their services. SuMeera Solutions maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our obligations under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, including the onward transfer provisions, and SuMeera Solutions remains liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

4. Sources of Personal Data

Information you provide to us directly, including when you register and communicate with us directly through our Digital Properties, visit our offices, or participate in our events, marketing, and outreach activities.
Information collected from your employer, coworkers, or friends, including information about representatives or other employees of our current, past, and prospective customers, suppliers, investors, and business partners. We may also receive your information from a friend as part of a referral for our Services.
Information automatically collected, including technical information about your interactions with our Digital Properties (such as IP address, browsing preferences, and purchase history). More information is available in Section 5 below and in our Cookie Notice.
Information from public sources, including information from public records and information you share in public forums, such as social media.
Information from other third parties, including information from third-party service and content providers, entities with whom we partner to sell or promote products and services, and social media networks (including widgets related to such networks, such as the “Facebook Like” button).

We may combine information that we receive from the various sources described in this Notice, including third-party sources and public sources, and use or disclose it for the purposes identified above.

5. Cookies and Tracking Technologies

We use cookies and other tracking technologies and offer you the option to manage these settings as described in our Cookie Notice. Some tracking technologies enable us to track your device activity over time and across devices and websites. While some browsers have incorporated Do Not Track or DNT preferences, we do not honor such signals from web browsers at this time.

6. Security and Retention

We maintain appropriate security procedures and technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, disclosure, alteration, or use.

Your personal data will be generally retained as long as necessary to fulfill the purposes for which we collected the personal data. Once you and/or your company have terminated the contractual relationship with us or otherwise ended your relationship with us, we may retain your personal data in our systems and records to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to evidence our business practices and contractual obligations, to provide you with information about our products and services, or to comply with applicable legal, tax, or accounting requirements. When we have no ongoing legitimate business need nor lawful legal ground to process your personal data, we will delete, anonymize, or aggregate it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. If you want to know more about retention periods applicable to your particular circumstance, please contact us using the details provided in Section 12 below.

7. Children’s Privacy

Our Sites and Services are not directed to children under the age of 16, and we do not knowingly collect online personal data directly from children. If you are a parent or guardian of a minor child and believe that the child has disclosed online personal data to us, please contact us using the details provided in Section 12 below.

8. External Links

When interacting with us, you may encounter links to external sites or other online services, including those embedded in third-party advertisements. We do not control and are not responsible for privacy and data collection policies for such third-party sites and services. You should consult such third parties and their respective privacy notices for more information or if you have any questions about their practices.

9. Supplemental Terms for California Residents

Pursuant to the California Consumer Privacy Act (“CCPA”), this Section 9 applies to certain personal data collected about California individuals where SuMeera Solutions controls how and why the personal data is processed (which the CCPA calls a “business”) and supplements the rest of our Notice above. This Section 9 does not apply to current or former employees, applicants, contractors, or agents.

a. Additional Data Processing Disclosures:

Although we have not “sold” or “shared” personal data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a “sale” or “sharing” as defined under California law. We do not knowingly sell or share any personal data of minors under the age of 16. We do not collect or process “sensitive personal information,” as defined by California law, to infer characteristics about you. SuMeera Solutions only uses sensitive personal information consistent with the exceptions to the right to limit sensitive personal information.

Financial Incentives: We may offer a benefit or offering in exchange for you providing personal data, such as a discount or coupon to individuals who respond to a survey. As part of these surveys we may collect personal data, such as your name, contact information, preferences, experiences, beliefs, opinions, and other responses to the survey questions. Participation in surveys is governed by the applicable terms and conditions for the survey, which will describe any financial incentives associated with that survey and how to participate. The value of your data is the value of the offer presented to you. We have calculated such value by using the expense related to the benefit. You may withdraw from any financial incentive at any time by emailing us at contact@sumeerasolutions.com. If we offer another type of financial incentive, we will share with you the material terms of each offer when we ask you to participate.

b. Your Data Protection Rights:

Subject to legal limitations, certain California residents may have the below rights.

Right to Know. You have the right to request information about the categories of personal data we have collected about you, the categories of sources from which we collected the personal data, the purposes for collecting the personal data, the categories of third parties to whom we have disclosed your personal data, and the purpose for which we disclosed your personal data. You may also request information about the specific pieces of personal data we have collected about you (“Specific Pieces Report”).
Right to Delete. You have the right to request that we delete personal data that we have collected from you.
Right to Correct. You have the right to request that we correct inaccurate personal data that we maintain about you.
Right to Opt Out of Sale or Sharing. We do not sell personal data to third parties in exchange for money. However, as we explain in Section 5, we share information with advertising partners and allow advertising partners to collect information from our Digital Properties. This exchange may be considered a “sale” or “sharing” under California law, and you have the right to opt out of this “sale” or “sharing” of personal data.

California residents may request to exercise the Right to Know, the Right to Delete, and the Right to Correct by emailing us at contact@sumeerasolutions.com. We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

How to Fully Exercise the Right to Opt Out of Sale or Sharing: In order to fully exercise the Right to Opt Out of Sale or Sharing with respect to any “sale” or “sharing” of information, you must undertake both of the following steps:

Submit a Right to Opt Out of Sale or Sharing request by emailing us at contact@sumeerasolutions.com; and
Disable the use of advertising cookies and other tracking technologies by clicking the “Do Not Sell or Share My Personal Information” link in our website footer. You must complete this step on each of our Sites from each browser and on each device that you use. These steps are necessary so that we can place a first-party cookie signaling that you have opted out on each browser and each device you use.

If you block cookies, we will be unable to comply with your Right to Opt Out of Sale or Sharing request for device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies. If you clear the cookies in your browser, you will need to follow Step 2 above again. To the extent required by California law, we will honor “Do Not Sell or Share” opt-out preference signals sent in a format commonly-used and recognized by businesses at the browser level, such as an HTTP header field or JavaScript object.

Verification: To process California data protection requests, we will need to obtain information to locate you in our records or verify your identity, depending on the nature of the request. In most cases, we will request information about you, which may include your name, email address, or other information. If you submit a Right to Know - Specific Pieces Report we may also request a signed declaration, under penalty of perjury, that you are who you say you are. We may request alternative information under certain circumstances and/or use third parties to help verify your identity.

Authorized Agents: Authorized agents may exercise California data protection rights on behalf of California individuals, but we reserve the right to verify the individual’s identity directly as described above. Authorized agents must contact us by submitting a request by emailing us at contact@sumeerasolutions.com and indicate that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on your behalf by providing signed permission from you. We may also require you to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.

Timing: We will process Right to Opt Out of Sale or Sharing requests within fifteen (15) business days from the date we received the request. We will respond to Requests to Delete and Requests to Know within forty-five (45) days unless we need more time, in which case we will notify you, and it may take up to ninety (90) days to respond to your request.

10. Supplemental Information for the EEA, Switzerland, and the U.K.

The following terms supplement the Notice with respect to our processing of EEA (i.e., European Union Member States, Iceland, Liechtenstein, and Norway), Swiss, and U.K. personal data. In the event of any conflict or inconsistency between the other parts of the Notice and the terms of this Section 10, this Section 10 shall govern and prevail with regard to the processing of EEA, Swiss, and U.K. Personal Data, to the extent applicable.

Data Controller: The SuMeera Solutions entity with which you have a primary relationship (such as the entity that concluded the Services contract with you; the entity that has provided you with marketing materials and promotional communications; or the primary entity in the region where you access our Site) is the controller within the scope of this Notice. This will be SuMeera Solutions Inc., unless we specifically inform you otherwise.

a. Legal Basis for Processing:

Please see Section 3 for the legal basis on which we rely for the collection, processing, and use of personal data.

b. Your Data Protection Rights:

Under applicable data protection laws, you may exercise certain rights regarding your personal data.

You may exercise these rights by contacting us using the details provided in Section 12 or by visiting here to submit your request. Please note that we may refuse to act on requests to exercise data protection rights in certain cases, such as where providing access might infringe someone else’s privacy rights or impact our legal obligations.

c. International Transfers of Personal Data:

Due to the global nature of our operations, some of the recipients mentioned in Section 2 of the Notice may be located in countries outside the EEA, Switzerland, or the U.K., which do not provide an adequate level of data protection as defined by data protection laws in the EEA, Switzerland, and the U.K. Transfers to third parties located in such third countries take place using a valid data transfer mechanism, such as the EU Standard Contractual Clauses and/or the U.K. Addendum to such clauses, approved codes of conduct and certifications mechanisms, on the basis of permissible statutory derogations, or any other valid data transfer mechanism issued or approved by the EEA, Swiss, or U.K. authorities. Certain third countries have been officially recognized by the EEA, Swiss, and U.K. authorities as providing an adequate level of protection and no further safeguards are necessary. Please reach out to us using the contact information in Section 12, if you wish to receive further information about how we transfer personal data or, where available, a copy of the relevant data transfer mechanism.

SuMeera Solutions complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SuMeera Solutions has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. SuMeera Solutions has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit here

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, SuMeera Solutions commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit here for more information or to file a complaint. The services of JAMS are provided at no cost to you. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means.

The Federal Trade Commission has jurisdiction over SuMeera Solutions’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Data Protection Officer: The contact details for our data protection officer are as follows: SuMeera Solutions Inc., Attn: Privacy Team, 4660 La Jolla Village Drive, Suite 100, San Diego, CA 92122, United States, contact@sumeerasolutions.com.

EU Representative: The contact details for our Representative for GDPR purposes are as follows: Bradwell Limited, Ten Earlsfort Terrace, Dublin 2, D02 T380, Ireland.

11. Supplemental Information for Other Regions

Australia: Personal data collected, stored, used, and/or processed by SuMeera Solutions, as described in this Notice, is collected, stored, used, and/or processed in accordance with the Australian Privacy Act 1988 (Commonwealth) and the Australia Privacy Principles. If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting the OAIC using the methods listed here. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.

Canada: Personal data, as defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) will be collected, stored, used, and/or processed by SuMeera Solutions in accordance with the SuMeera Solutions’s obligations under PIPEDA.

Nevada: We do not presently sell personal data as defined under Nevada law. If you are a Nevada resident, you may nevertheless email us using the information above to exercise your right to opt-out of sale under Nevada Revised Statutes §603A et seq.

12. Contact Information

If you have questions or complaints regarding this Notice or about the SuMeera Solutions’s privacy practices, please contact us by email at contact@sumeerasolutions.com, or at:

2305 D , Nantucket Drive,
Houston, Texas, 77057

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. to JAMS, a DPF an alternative dispute resolution provider based in the United States.

13. English Version Controls

Non-English translations of this notice are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.