Basic Information about Data Protection

Controller
REBECCA TECHNOLOGY LTD
Website
https://supabrush.com
Purposes and legal basis
- Providing you with and managing our Services (Performance of contractual relationship)
- To improve Services, conduct surveys and prevent fraud and abuse (Legitimate interest)
- To send you commercial information about our Services (Legitimate interest or consent, as applicable)
- To answer queries, requests suggestions and complaints (Performance of contractual relationship, legitimate interest or consent, as applicable)
Recipients
We will share your personal data with service providers who help or support us, with public administrations or those with whom we have a legal obligation. International transfers of user data may be made, always with sufficient guarantees to comply with the provisions of the applicable regulations.
International transfers of user data
May be made, always with sufficient guarantees to comply with the provisions of the applicable regulations.
Rights of the data subject
You have the right to access, rectify, erase, object, request limitation or portability or not be subject to automated individualized decisions of your personal data, as we explain in detail below. You can direct your request to [email protected]. You can also request the assistance of the data protection authority of the country you are based on through its website.
Additional information
For more information, we suggest that you read the full version of this Privacy Policy below. You can also consult our Terms of Service.

Your privacy is important to Supabrush ("Supabrush" or "us"). This Privacy Policy explains how we collect, use and manage your personal data when you ("User" or "you") browse our website https://supabrush.com, including any of its subdomains or sections ("Website") or when you use our services through the Website ("Services").Supabrush will process personal data in accordance with applicable data protection regulations.

We recommend that you read carefully this Privacy Policy before contracting our Services or browsing our Website.

1. What data we process and what are the purposes

1.1. Information obtained during the use of the Services by Users

During the registration process and the provision of the Services, Supabrush may process personal data provided by Users, including:

Identification data which may vary depending on the selected authentication method.
Economic and transactional information (e.g. your payment details, information about your subscription to our Services, data provided in the scope of the provision of Services, etc).

These personal data are used by Supabrush for the following purposes:

Supabrush may use the personal data described to provide the Services and carry out the maintenance and management of the contractual relationship, including the sending of notifications necessary for the proper provision of the Services. In this case, the legal basis for the processing of the described data is the performance of the contractual relationship between the User and Supabrush for the provision of the Services.
Supabrush may also process personal data to manage and improve the Services, including the possibility of submitting alternatives or modifying the Services based on the use, responding to suggestions, conducting surveys and satisfaction analysis, as well as preventing fraud and abuse. The legal basis for the processing of the data described for this purpose will be the legitimate interest, since we understand that it is also beneficial for you because, on one hand, the purpose is to improve the User’s experience and offer higher quality Services and, on the other, performing the necessary checks to detect and prevent possible frauds or fraudulent uses allows us to implement measures to protect you against attempted fraud by third parties or misuse of our Services.
Occasionally, Supabrush may send commercial information and news to Users, where applicable, in relation to the contracted Services, as well as information regarding promotional activities carried out in relation to them. If you do not wish to receive certain commercial communications from us, you can click on the "unsubscribe" link in the corresponding email or communicate it to us via [email protected]. The legal basis for the processing of personal data for this purpose is Supabrush’s legitimate interest in informing Users about news and promotional actions related to the Services, unless Users inform Supabrush that they do not wish to receive commercial communications. The legal basis may also be the consent of the User, in the event that the User has given its consent to Supabrush to receive commercial communications.
Supabrush may process the data described to comply with the regulations that are applicable in each case and to respond to requests of the public authorities, in which case, the legal basis for the processing of the data will be the fulfillment of the legal obligation applicable to the case.

1.2. Information obtained through other contact means by users of the Website

Supabrush may obtain personal data from users of the Website through Supabrush’s e-mail address or Supabrush’s team members’ contact addresses (including through social media) for the following purposes:

To respond to queries, requests, suggestions or complaints. The personal data of users of the Website (for example, contact details or first and last name) received by Supabrush through the means enabled for this purpose, will be used exclusively to respond to queries, requests, suggestions or complaints sent by users who access and browse the Website.

The legal basis for the processing of these data will be either:

Supabrush’s legitimate interest in responding to requests, suggestions or queries raised
Compliance with legal obligations on our part, if the query is related to the exercise of the rights about which we inform you below.

2. How long we keep your personal data

On a general basis, personal data will be kept for the time necessary to fulfill the purpose for which they were collected and, afterwards, for the periods established by the applicable regulations to comply with legal obligations. In particular:

When the legal basis for the processing of your personal data is the performance of the contractual relationship, we will process your data for the duration of such contractual relationship.
The data processed to respond to queries, requests, suggestions or complaints, will be kept for as long as necessary to respond to such queries, requests, suggestions or complaints.
The data processed to send you commercial communications will be processed until you request their cancellation in the receipt of said commercial communications.
The information obtained to manage and improve the Services, including the possibility of conducting surveys and satisfaction analysis, as well as preventing fraud and abuse, will be treated punctually during the time in which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data.

After the end of the retention periods, the data will be blocked for the period of time necessary to meet any type of liability, as required by the applicable regulations depending on the case (e.g. until the limitation of the liability that may arise from the regulations on data protection).

3. To whom we provide your personal data

Supabrush collaborates with some third party service providers who have access to our personal data and who process it on behalf of Supabrush as a result of the provision of services. In its commitment to the privacy and protection of the Users’ data, Supabrush will only choose companies that offer sufficient guarantees to apply appropriate technical and organizational measures, with which it will sign agreements that guarantee the protection of the rights of the data subjects, so that the processing is in accordance with the applicable legislation on data protection.

More specifically, Supabrush will contract the provision of services by third-party providers that carry out their activity, by way of example and not limited, in the following sectors: financial services, IT and technology service providers, messaging service providers and digital marketing service providers.

If you are based in the European Economic Area (EEA), Switzerland or the United Kingdom, please note that we will transfer your personal data to recipients outside such territories for the purposes described in this Privacy Policy. If your personal data is transferred to a third country, that third country may not offer the same level of data protection as your home country. However, we transfer personal data pursuant to applicable data protection laws. To transfer your personal data outside of the EEA, Switzerland or the UK, we rely on the European Commission’s adequacy decisions on certain countries and, for other jurisdictions, we rely on the Standard Contractual Clauses at the following link: https://ec.europa.eu/consumers/odr/.

4. What are your rights as a data subject

We inform you that in accordance with current legislation you have the right to exercise your rights of access, rectification, as well as the right to erasure or object, limitation of processing, the right to the portability of your data and the right to withdraw the consent for the processing of personal data that you have consented to at any time, proving your identity (by copy of ID card or equivalent) by sending an email to [email protected].

If you believe that Supabrush has not respected any of the aforementioned rights, you have the right to contact the data protection authority of the country you are based on through its official website.

5. Cookies policy

Our Website uses cookies to improve the user experience. Cookies are small text files that are stored on your device and allow us to collect data about your activity on the Website. In general, these technologies can serve a wide variety of purposes, such as, for example, recognizing you as a user, obtaining information about your browsing habits, customizing the way the content is displayed or to provide you with certain functionalities or services on the relevant website.

Cookies can be of different types depending on the purpose for which they are used. We only use cookies to allow your browsing through our Website and the use of the different options that exist on it, including those that we use to allow the management and operation of this Website and enable its functions (technical cookies).

In this regard, we inform you that we use cookies that are exempt from the obligations established by the applicable regulations to require your consent. Cookies we are using are strictly necessary cookies:

visualJsid (Save the information on the status of acceptance of cookies. Necessary for the proper functioning of the web).
__gsas, _ga (Provides information on user behavior for statistical purposes and improvement of the platform. Google Analytics 4 does NOT log or store IP addresses).