PRIVACY POLICY
Last Updated: January 30, 2025
Thank you for choosing to be part of our community at SOOS, LLC, doing business as SOOS (“SOOS,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy, or our practices with regard to your personal information, please contact us at support@SOOS.io.
When you visit our website https://soos.io ("Website"), and more generally, use any of our services (the "Services," which include the Website), we understand that you are trusting us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain what information we collect, how we use it, and what rights you have in relation to it. If you do not agree with any terms in this privacy policy, please discontinue use of our Services immediately.
This privacy policy applies to all information collected through the Services (which, as described above, includes our Website), as well as any related services, sales, marketing, or events.
1. What Information Do We Collect?
2. How Do We Use Your Information?
3. Will Your Information Be Shared With Anyone?
4. How Long Do We Keep Your Information?
5. How Do We Keep Your Information Safe?
6. Do We Collect Information From Minors?
7. What Are Your Privacy Rights? (Including Data Subject Rights)
8. Tracking Features and Use of Cookies
9. Do California Residents Have Specific Privacy Rights?
10. Legal Basis for Processing (GDPR)
11. International Data Transfers
13. Supervisory Authority Contact
14. Do We Make Updates to This Policy?
15. How Can You Contact Us About This Policy?
1. What Information Do We Collect?
We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website, or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make, and the products and features you use. The personal information we collect may include the following:
Personal information provided by you. We collect names, phone numbers, email addresses, mailing addresses, job titles, usernames, passwords, contact preferences, contact or authentication data, and other similar information.
Personal information we do NOT collect. We will not collect or store any payment processing details (e.g., credit card numbers, security codes). All payment data is stored by our third-party payment processor. See their privacy policy at: https://stripe.com/privacy. We will never collect your social security number or personal information unrelated to the services provided to you (e.g., race, religion, gender, sexual orientation).
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information Automatically Collected
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website or Services. This log data may include your IP address, device information, browser type and settings, pages and files viewed, and other system activity details.
Device Data. We collect information about the device(s) you use to access the Website (e.g., IP address, device application identification numbers, location, browser type, hardware model, mobile carrier, operating system configuration).
Location Data. We may collect information about your device’s location, which can be precise or imprecise (e.g., based on IP address). You can opt out by refusing access to location or disabling location settings on your device. Note, however, that some Services may not function properly if location data is restricted.
Information Collected from Other Sources
We may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, and other third parties. This may include mailing addresses, job titles, email addresses, phone numbers, intent data, IP addresses, social media profiles, and social media URLs.
2. How Do We Use Your Information?
We use personal information collected via our Website for a variety of business purposes. We process your personal information for our legitimate business interests, to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. Specifically, we use the information we collect or receive to:
Facilitate account creation and logon processes.
Request feedback.
Manage user accounts and keep them in working order.
Send administrative information (e.g., product, service, new feature info, changes to our terms).
Protect our Services (fraud monitoring and prevention).
Enforce our Terms of Service.
Comply with legal and regulatory requirements, respond to legal requests, and prevent harm.
Deliver and facilitate delivery of services to the user.
Respond to user inquiries/offer support to users.
Send marketing and promotional communications in accordance with your preferences. You can opt out anytime.
Deliver targeted advertising to you, unless you opt out.
3. Will Your Information Be Shared With Anyone?
We may process or share your data based on the following legal bases:
Consent: You have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: Processing is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we process your personal information to fulfill contractual terms.
Legal Obligations: We may disclose your information where required by law or to comply with a subpoena or similar legal process.
Vital Interests: We may share information where necessary to prevent potential violations of our policies or illegal activities, or as evidence in litigation.
Business Transfers: In connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business.
4. How Long Do We Keep Your Information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements). No purpose in this policy requires us to keep your personal information for longer than three (3) months past the termination of the user’s account and use of our Services.
Additional Data Retention Statement
We retain your personal data only for as long as necessary to:
– Fulfill the purposes for which it was collected,
– Comply with legal obligations, or
– Resolve disputes and enforce agreements.
Retention periods may vary based on the type of data and processing purpose. For specific retention details, please contact us at support@soos.io.
When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize such information. If deletion or anonymization is not possible (for example, if your personal information is stored in backup archives), we will securely store it and isolate it from further processing until deletion is feasible.
5. How Do We Keep Your Information Safe?
We have implemented appropriate technical and organizational security measures to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed 100% secure. Therefore, we cannot promise or guarantee that unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. You should only access the Website within a secure environment.
6. Do We Collect Information From Minors?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of a minor and consent to the minor’s use of the Website. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to delete such data. If you become aware of any data we may have collected from children under 18, please contact us.
7. What Are Your Privacy Rights? (Including Data Subject Rights)
General Privacy Rights
If you reside in the European Economic Area (EEA) and believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority. (See Supervisory Authority Contact below.)
Account Information
If you would like to review or change the information in your account or terminate your account, you can:
– Log in to your account settings and update your user account, or
– Contact us using the contact information provided below.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, though some information may be retained to prevent fraud, troubleshoot issues, or comply with legal requirements.
Opting Out of Email Marketing
You can unsubscribe from our marketing email list at any time by clicking the “unsubscribe” link in our emails or by contacting us. You may still receive non-marketing emails necessary for the administration of your account or to respond to service requests.
Additional Data Subject Rights Under GDPR
Under applicable data protection laws (including GDPR), you may have the following rights regarding your personal data:
Right of access: Obtain confirmation whether we process your personal data and access a copy of it.
Right to rectification: Request correction of inaccurate or incomplete personal data.
Right to erasure (“right to be forgotten”): Request deletion of your personal data under certain conditions.
Right to restriction of processing: Request limited use of your personal data under certain circumstances.
Right to data portability: Receive a copy of your personal data in a structured, commonly used, machine-readable format.
Right to object: Object to processing of your personal data for specific purposes (e.g., direct marketing).
To exercise these rights, please contact us at support@soos.io. We will respond within the time frames required by applicable laws.
8. Tracking Features and Use of Cookies
Our Website uses cookies and similar tracking technologies to distinguish you from other users, improve functionality, and enhance efficiency. By continuing to use our Website, you agree to our use of cookies as described below.
Types of cookies we use include:
Necessary / Essential Cookies: Critical for enabling core site functionality (e.g., logging in, security).
Performance Cookies: Collect information about your online activity (e.g., pages visited) to help us analyze and improve our Services.
Functionality Cookies: Remember settings (e.g., language) to personalize your experience.
Marketing or Advertising Cookies: Track browsing activity to deliver tailored advertising, if applicable.
You can manage or disable cookies in your browser settings. However, blocking all cookies (including essential ones) may affect the functionality of our Services. For more details on how we use cookies and how you can manage them, please contact us at support@soos.io.
9. Do California Residents Have Specific Privacy Rights?
California Civil Code Section 1798.83 (“Shine The Light”) permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes. If applicable, submit your request in writing to us using the contact information below.
If you are under 18, reside in California, and have a registered account, you may request the removal of unwanted data publicly posted on the Website. We will ensure the data is not publicly displayed on the Website but please be aware it may not be completely removed from all our systems.
CCPA Privacy Notice
California defines a “resident” to include:
Every individual in California for other than a temporary or transitory purpose, and
Every individual domiciled in California who is outside California for a temporary or transitory purpose.
If you are a California resident, certain rights and obligations apply:
What categories of personal information do we collect?
Refer to section 1, "What Information Do We Collect?" for details on the categories of personal information we collect.
Will your information be shared with anyone else?
We may disclose your personal information to service providers pursuant to a written contract. We do not “sell” personal information as defined by the CCPA, and we will not do so without your explicit permission.
Your rights with respect to your personal data (under CCPA):
– Right to request deletion of your personal information (subject to certain exceptions).
– Right to non-discrimination for exercising any CCPA rights.
– Right to correct, object, or restrict certain data processing.
– Right to designate an authorized agent to make a request on your behalf.
10. Legal Basis for Processing (GDPR)
We process your personal data under one or more of the following legal grounds:
Consent: When you have provided explicit consent.
Contract: When processing is necessary to perform a contract with you or to take steps before entering into a contract.
Legal Obligation: When processing is necessary for compliance with a legal obligation.
Legitimate Interests: When processing is necessary for our legitimate interests (e.g., improving our services), provided these interests do not override your fundamental rights and freedoms.
11. International Data Transfers
We may transfer your personal data outside the European Economic Area (EEA), including to the United States, where data protection laws may differ from those in your jurisdiction. When we do so, we ensure appropriate safeguards are in place, such as:
Standard Contractual Clauses (SCCs) approved by the European Commission.
Participation in recognized privacy frameworks (e.g., the EU-U.S. Data Privacy Framework, if applicable).
Supplementary measures (e.g., encryption, access controls) to protect your data.
12. Third-Party Data Sharing
We may share your personal data with trusted service providers and sub-processors who help us deliver our Services. These entities are contractually obligated to comply with applicable data protection laws and to safeguard your data. Examples include:
Hosting and infrastructure providers: For secure data storage and access.
Analytics providers: To help us understand and improve how users interact with our Services.
Support providers: To assist with technical and customer support inquiries.
For a list of current sub-processors, please visit our Sub-Processor List at: https://soos.io/sub-processors
13. Supervisory Authority Contact
If you believe our data processing practices violate applicable data protection laws, you have the right to lodge a complaint with a supervisory authority. For EU residents, this is typically the data protection authority in your country of residence. You can find EU supervisory authority contact details at:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you reside in Switzerland, the contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html
14. Do We Make Updates to This Policy?
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and will be effective as soon as it is accessible. If we make material changes, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this policy frequently to stay informed about how we are protecting your information.
15. How Can You Contact Us About This Policy?
If you have questions or comments about this policy, you may email us at support@soos.io, or by post to:
SOOS, LLC
20 Winooski Falls Way
Suite 302
Winooski, VT 05404
United States