PRIVACY POLICY

VERSION 1.0

EFFECTIVE: JUNE 25, 2024

1. Introduction

The purpose of this privacy policy (the "Privacy Policy") is to inform future prospects, customers, consultants, partners, service providers, and suppliers (including their employees) and more generally anyone browsing Manila Research, LLC's website at the following address https://www.supacrawler.com/ (the "Website") and use Manila Research, LLC's services about how Manila Research, LLC ("Manila Research", "Supacrawler", "we", "us", or "our") processes Personal Data.

In this Privacy Policy, We seek to explain to You in the clearest way possible what Personal Data We collect, how We use it, and what rights You have in relation to it. We hope you take some time to read through it carefully as it is important. If there are any terms in this Privacy Policy that You do not agree with, please discontinue the use of our Website and our services.

2. Definition

For the purpose of the Privacy Policy, notably, the terms "Personal Data," "Processing," "Data Subject," "Data Controller," "Data Processor," and "Personal Data Subject" have the meaning given by the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (the "GDPR") and the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

3. Who is Data Controller and Data Subjects?

In short: Manila Research is Data Controller and You are Data Subjects

Manila Research is responsible for all data processing in its professional capacity and within its business activity. In this capacity, Manila Research is subject to the obligations imposed upon it by applicable data privacy regulations.

Data subjects are suppliers, service providers, consultants, partners, customers, and prospects as well as their employees and more generally anyone using the Website (the "Users" or "You").

In the event our Website or services contain links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, You should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

4. What Personal Data do we collect?

We collect and process the following types of Personal Data:

• Account Data: Email address, name, and authentication information when you create an account
• Usage Data: Information about how you use our services, including API requests, timestamps, and IP addresses
• Payment Data: When you subscribe to our paid services, we collect billing information through our payment processor (Stripe)
• Technical Data: Browser type, device information, operating system, and cookies

Personal Data automatically collected

We automatically collect certain information when You visit, use, or navigate the Website and our services. This information does not reveal Your specific identity (like your name or contact information) but may include device and usage information such as Your IP address, device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and services, and other technical information. This information is primarily needed to maintain the security and operation of our Website and services, and for Our internal analytics and reporting purposes. Like many businesses, We also collect information through cookies and similar technologies.

Personal Data that You provide Manila Research with

Manila Research collects Personal Data directly from Users, notably via data collection forms on the Website or otherwise or during meetings, trade discussions, email exchanges, or as part of performing a contract. This Personal Data is updated directly by Users. To this end, any update of said Personal Data must be immediately communicated to the relevant Manila Research department (marketing department/customer service accounts, etc.).

Personal Data obtained through authentication providers

We offer the ability to sign in using third-party authentication providers. When you choose to authenticate using Google or GitHub, we receive certain profile information from these providers. The specific information we receive depends on your privacy settings with these services. This typically includes your name, email address, and profile picture. The privacy policies for these authentication providers can be viewed at the following links:

• Google Privacy Policy
• GitHub Privacy Policy

Additionally, Manila Research collects Personal Data using cookies and/or tracers that can analyze the behavior of web users.

Manila Research may also receive Personal Data about You via banking or credit institutions. In such cases, We will update Your Personal Data in Our database.

Personal Data regarding third parties that You provide Manila Research with

If You provide us with Personal Data relating to somebody else (e.g. your employees' Personal Data for maintenance purposes or for partner recommendations), You guarantee that You have the authority to consent to the processing of Data on their behalf or more generally to communicate said Personal Data to us and that You receive any correspondence relating to their Personal Data on their behalf.

The type of Data being processed

Personal Data collected as part of a processing operation is strictly limited to the purpose for which it has been collected. As such, the Personal Data that we collect from prospects include first and last names, a work email address, employer details, work phone number, and browsing data (cookies).

In addition to the above Personal Data, we process the following Personal Data concerning Users and their employees: IP address, function, login, and login details.

Personal Data relating to suppliers is as follows: First and last names, email address, contact phone number, banking details, contract documents, and qualifications.

5. Cookies and Tracking Technologies

Cookie Usage

We use only essential cookies that are necessary for the proper functioning of our website and services. These cookies are used for authentication, session management, and security purposes. They are strictly necessary to provide you with the services you have requested and to use some of their features.

These essential cookies do not require your consent under applicable laws, as they are required for the website to function properly. We do not use any marketing, analytics, or tracking cookies that would require explicit consent.

The essential cookies we use:

• Authentication cookies: To remember your login status
• Session cookies: To maintain your session while using our services
• Security cookies: To help protect your account and our platform

You can control cookies through your browser settings. Most web browsers allow you to manage your cookie preferences. You can set your browser to refuse cookies, or to alert you when cookies are being sent. However, if you disable cookies, some features of our services may not function properly.

6. What is Manila Research's lawful basis for processing Personal Data?

In short: We process Your Personal Data for purposes based on legitimate business interests, the fulfillment of Our contract with You, compliance with Our legal obligations, and/or Your consent.

We will only collect and use Your Personal Data when we have a legal right to do so. In which case, we will collect and use Your Personal Data lawfully, fairly, and in a transparent manner.

Our lawful bases depend on the services You use and how You use them. This means We only collect and use Your Personal Data on the following grounds:

• Consent From You: Where You give us consent to collect and use Your Personal Data for a specific purpose. You may withdraw Your consent at any time using the features we provide; however, this will not affect any use of Your Personal Data that has already taken place. You may consent to provide Your email address for the purpose of receiving marketing emails from Us. While You may unsubscribe at any time, We cannot recall any email We have already sent. If You have any further inquiries about how to withdraw Your consent, please feel free to inquire using the details provided hereinafter.
• Performance of a Contract or Transaction: Where You have entered into a contract or transaction with Us or in order to take preparatory steps prior to Our entering into a contract or transaction with You. For example, if You contact Us with an inquiry, We may require Personal Data such as Your name and contact details in order to respond.
• Our Legitimate Interests: Where We assess it is necessary for Our legitimate interests, such as for Us to provide, operate, improve, and communicate Our services. We consider Our legitimate interests to include research and development, understanding Our audience, marketing, and promoting Our services, measures taken to operate Our services efficiently, marketing analysis, and measures taken to protect Our legal rights and interests.
• Compliance with Law: In some cases, We may have a legal obligation to use or keep Your Personal Data. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If You have any further inquiries about how We retain personal information in order to comply with the law, please feel free to inquire using the details provided in the Contact Us section of this Privacy Policy.

7. How do Manila Research use Your Personal Data?

In short: We process Your Personal Data for the provision of our services, legitimate business interests, compliance with Our legal obligations, and/or Your consent.

Depending on how You interact with our Website and services, We may use Your Personal Data to:

• Facilitate account creation and authentication and otherwise manage user accounts. We may use Your Personal Data to facilitate account creation and the login process.
• Deliver and facilitate delivery of services to the user. We may use Your Personal Data to provide You with the requested service.
• Respond to user inquiries and offer support to users. We may use Your Personal Data to respond to Your inquiries and solve any potential issues You might have with the requested service.
• Send administrative information to You. We may use Your Personal Data to send You product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
• Request feedback. We may use Your Personal Data to request feedback and to contact You about Your use of our Website and services.
• To protect our services. We may use Your Personal Data as part of our efforts to keep our Website and services safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
• To respond to legal requests and prevent harm. If We receive a subpoena or other legal request, We may need to inspect the data We hold to determine how to respond.
• Fulfill and manage Your orders. We may use Your Personal Data to fulfill and manage Your orders, payments, returns, and exchanges made through the Website and services.
• Administer prize draws and competitions. We may use Your Personal Data to administer prize draws and competitions when You elect to participate in our competitions.
• To deliver and facilitate delivery of services to the user. We may use Your Personal Data to provide You with the requested service.
• To respond to user inquiries/offer support to users. We may use Your Personal Data to respond to Your inquiries and solve any potential issues You might have with the use of our services.
• To send You marketing and promotional communications. We and/or our third-party marketing partners may use the Personal Data You send to us for our marketing purposes, if this is in accordance with Your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website and services, subscribing to marketing, or otherwise contacting us, We will collect Personal Data from You. You can opt-out of our marketing emails at any time (see the "What Are Your Privacy Rights?" section below).
• Deliver targeted advertising to You. We may use Your Personal Data to develop and display personalized content and advertising (and work with third parties who do so) tailored to Your interests and/or location and to measure its effectiveness.

8. Will Your Personal Data be shared with anyone?

In short: We only share Personal Data with Your consent, to comply with laws, to provide You with services, to protect Your rights, or to fulfill business obligations.

We may process or share Your Personal Data based on the following legal basis:

• Consent: We may process Your Personal Data if You have given us specific consent to use Your Personal Data for a specific purpose.
• Legitimate Interests: We may process Your Personal Data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with You, We may process Your Personal Data to fulfill the terms of our contract.
• Legal Obligations: We may disclose Your Personal Data where We are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose Your Personal Data where We believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which We are involved.

More specifically, We may need to process Your Personal Data or share Your Personal Data with the following third parties:

• Business Transfers. We may share or transfer Your Personal Data 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.
• Vendors, Consultants and Other Third-Party Service Providers. We may share Your Personal Data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website and services, which will enable them to collect data on our behalf about how You interact with our Website and services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages, or features, and better understand online activity. Unless described in this notice, We do not share, sell, rent, or trade any of Your Personal Data with third parties for their promotional purposes.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when You visit or use the Website or services. These companies may use information about Your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to You.

9. How long do we keep Your Personal Data?

We will only keep Your Personal Data 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.

• Personal Data relating to prospects or Customers is retained for as long as you maintain an active account with us, and for a period of 3 years after your last interaction with our services
• Scraping data and job results are retained indefinitely unless you specifically request deletion
• Payment information is retained in accordance with financial and tax regulations
• Pre-litigation: Personal Data is held until a settlement agreement has been concluded or failing this until the corresponding legal action has been prescribed
• Judicial litigation: Data is held until the decision has the force of res judicata

When we have no ongoing legitimate business need to process Your Personal Data, we will either delete or anonymize it, or if this is not possible (for example, because your personal information 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.

Furthermore, anonymous data and data relating to Users may be held for an unlimited period of time when it does not contain or no longer contains any Personal Data.

10. Actions carried out on Personal Data

In short: We carry out actions on Your Personal Data to achieve the purposes described in this Privacy Policy.

The following actions are carried out on Personal Data:

• Collection and recording
• Organization and structuring
• Hosting or retention using third-party software
• Consultation / visualization
• Personal Data sorting (using a solution published by a third party)
• External archiving
• Transmission, distribution, or otherwise in any form making available of the concerned services
• Modification/consultation by customer service, marketing, accounts, or IT department
• Deleting, destroying, or anonymization

11. Personal Data localization and existing safety measures

Your Personal Data is stored and processed on Google Cloud Platform servers located in the US Central region (us-central1-a). We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction.

12. Do Manila Research collect Personal Data from minors?

In short: Manila Research does not knowingly collect or process by any means Personal Data from Data Subjects under 18 years old.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, You represent and warrant that You are at least 18. If We learn that Personal Data from users less than 18 years of age has been collected, We will deactivate the Account and take reasonable measures to promptly delete such Personal Data from our records. If You become aware of any Personal Data We have collected from children under the age of 18, please contact Us at the addresses indicated hereinafter.

13. What are Your privacy rights?

In short: You may review, change, or delete Your Personal Data at any time.

Users have the following rights on their Personal Data processed by Us:

• Access to or obtain a copy of their Personal Data.
• Rectification of their Personal Data.
• Have all or part of their Personal Data deleted when the Personal Data (i) is no longer needed for the purposes for which it was collected (ii) is exclusively based on User's consent (iii) and their Processing undergoes an objection proceeding.
• Limit the processing of their Personal Data temporarily when the accuracy of said Personal Data is challenged, when the User has objected to its processing, and when the Personal Data is no longer needed by Manila Research but is still mandatory for the establishment, exercise, or advocacy of their rights in court.
• Unsubscribe or opt out of receiving marketing messages at any time by clicking on the "unsubscribe" link in any emails or communication sent by Manila Research.
• Object to the Processing or withdraw their consent at any time when Personal Data processing is based on consent.
• Portability of their Personal Data when Personal Data is processed based on consent and when the processing is carried out using automated processes.
• Decide what happens to their Personal Data after their death.
• File a complaint with the local control's authority.

To exercise their rights or for any questions relating to this Privacy Policy, Users may contact Manila Research at the following address: hello@supacrawler.com and attach a copy of their ID card.

For individuals submitting a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom the request is made.

14. Updates

In Short: We will update this Privacy Policy as necessary to stay compliant with relevant laws and to reflect updates to Our business processes or practices. Any modifications will be enforceable after the Effective date.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify You either by prominently posting a notice of such changes or by directly sending You a notification. We encourage You to review this Privacy Policy frequently to be informed of how we are protecting Your information.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Manila Research, LLC
Email: hello@supacrawler.com

Last updated: June 25, 2024

16. Third-Party Services

Stripe

We use Stripe for payment processing. When processing payments through Stripe, some of your data will be passed to Stripe, including information required to process or support the payment, such as the purchase amount and billing information.

Please see the Stripe Privacy Policy for more details: https://stripe.com/privacy

Supabase

We use Supabase for authentication and database services. When you create an account or use our services, some of your data will be stored in Supabase's systems.

Please see the Supabase Privacy Policy for more details: https://supabase.com/privacy