Privacy Policy

Your privacy is important to Superna USA, Inc. and its affiliates (collectively “Superna,” “we,” or “us”).  This document describes the information practices for Superna and the websites operated by Superna or its affiliates, including but not limited to  https://superna.io/ and https://www.supernaeyeglass.com/ (the “Sites”) and products and services provided by Superna (the “Offerings”), including what type of information is collected and tracked, how the information is used, and with whom the information is shared.  As described below, this statement applies to your interactions with the Sites as well as other interactions with Superna, such as when you agree to Superna’s Terms of Use (“TOU”) or provide information to Superna.  BY USING THE SITES, YOU INDICATE YOUR UNDERSTANDING AND ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THESE TERMS, DO NOT USE THE SITES.  Please carefully read this Privacy Policy as it may have changed since your last visit to the Sites.  Continued use of the Sites indicates your understanding and acceptance of any changes made to this Privacy Policy posted to the Sites.  This Privacy Policy does not cover the privacy practices of any third-party websites to which the Sites may link.  For capitalized terms not defined herein, please see the definitions provided in the TOU.

Information Collected by Superna: This Privacy Policy applies to all information collected by or submitted to Superna (or carefully selected third parties acting on our behalf), including both personally identifiable information (“PII”) and non-personally identifiable information (“Non-PII”). PII refers to information that identifies you directly, such as your name, business affiliation and position, postal address, telephone number, e-mail address. We collect PII only when you voluntarily provide it to us. Non-PII refers to information that does not identify you personally, which we use to track your use of the Sites. For instance, we may collect information about what type of Web browser you use, and what pages of the Sites you visit to understand how the Sites are being used. You do not need to provide personally identifiable information to simply browse the Sites, and you have the right to request that the Sites delete your personally identifiable information. You are solely responsible for the accuracy, quality, and legality of information collected from you by or on behalf of Superna, and you represent and warrant that you have the right to provide that information. 

Superna may collect your PII when you:

• submit questions or comments to Superna;
• utilize the live Superna chat box on the Site;
• request information or materials from Superna;
• participate in surveys from or provide Feedback to Superna; 
• request a demo of any Offering;
• purchase an Offering from Superna, or any Superna reseller;
• register for an Offering;
• inquire about or apply for a position at Superna
• request or use Technical Support or Professional Services; or
• you submit any such information to Superna.

The types of PII collected may include (but are not limited to):

• your first and last name;
• your business physical address (including street name, city/town, state/province, country, postal code);
• your e-mail address;
• your telephone number; and
• any other identifier that permits Superna to make physical or online contact with you.

The types of Non-PII collected may include (but are not limited to):

• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information and click tracking
• Cookies and other tracking technologies (see below for more information)
• Usage Data and Product Data, as defined in the applicable Superna HYPERLINK “https://manuals.supernaeyeglass.com/project-eula-and-support-agreement/HTML/superna-eyeglass-eula-and-support-services-agreement.html” Agreement 

How Superna Uses Your Information: Superna collects and uses your information, including your PII, to operate and improve the Sites, and deliver and improve the Offerings, or carry out the transactions you have requested. These uses may include providing you with more effective customer service; making the Sites or Offerings easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our Offerings, and technologies; and displaying content and advertising that are customized to your interests and preferences.

We also use your personal information to communicate with you. We may send certain communications such as welcome letters, information updates, billing information, information on technical service issues, and security announcements. We may also contact you to inform you of Offerings available from Superna and its affiliates.

Sharing of Your Personal Information: Superna will not sell, rent, or lease your information, including your PII, to others. Superna shares personal information with companies working on our behalf. Superna also utilizes third parties to collect information on our behalf, any information you share with these third parties is subject to their privacy policies. A list of third parties used by Superna includes (but is not limited to): Zendesk, HubSpot, Salesforce, Gravity Forms, Google, Google Tag Manager, Google Analytics and Ads, and LinkedIn Ads. Superna also may share your PII with certain third parties in connection with providing the Offerings, including those certain subprocessors (a list of which is available upon request from Superna). Except as described in this statement, we will not disclose your personal information to third parties for their own marketing purposes unless you have provided consent. 

If you request something from the Sites (for example, a scheduled demo, a callback, or specific marketing materials), we will use the information you provide to fulfill your request or inquiry. To help us do this, we may share information with others, such as Superna’s business partners, resellers or distributors, financial institutions, shipping companies, and postal or government authorities involved in fulfillment. As part of a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting websites, processing transactions, tracking website engagement metrics, or performing statistical analysis of our Offerings. Such companies will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

We may access or disclose your information, including your PII, if we believe such action is necessary to: (a) comply with the law or legal process served on the Sites or Superna; (b) protect and defend the rights or property of the Sites or Superna (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of users of Superna’s Sites or Offerings or members of the public.

Your Choices: Superna provides a number of ways for you to “opt-out” of receiving certain information from us or having us provide your personal information to our partners. We may offer you these choices at the time you give us your personal information. 

If you do not wish to continue receiving certain marketing materials (e.g., e-mail messages), you can opt out of receiving these materials by following the unsubscribe instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, service updates, or other administrative and transactional notices.

How to Update Your Information: To update your Account Information, please email us at privacy@superna.io.

Safeguarding Your Personal Information: In order to protect your information, including your PII, from improper disclosure, Superna uses commercially reasonable efforts to maintain a secure operating environment to protect any information we collect. We use the most accurate and current information you provide in order to process your request. Once received, we limit access to your information to only those personnel with a legitimate business need to review them. Browsers offer varying degrees of security, particularly in regard to encryption. Even the same version of a browser can come with different levels of encryption. All acceptable browsers do provide detailed information on security levels in “Properties” or “Document Information” from the browser’s menu bar. See your browser’s “Help” tab or documentation for more information. Finally, we take care to dispose of your information properly so that third parties will not be able to access it. This includes destroying, erasing, or making unreadable the information. While we are committed to protecting your privacy, please be aware that no transaction over the Internet can be completely secure.

Enforcement of this Privacy Policy: Superna regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this statement or Superna’s Sites treatment of PII by contacting us at the link or address indicated below.

Cookies and Browser Information: Superna may use cookies for a variety of purposes. Cookies are small text files that a website sends to a Web browser, which are stored on the site visitor’s computer. Cookies are commonly used to track Web activity and provide an enhanced experience when using the internet. Superna may use cookies to collect information.  We use cookies to help us better understand website usage in the aggregate so that we know what areas of the Sites users prefer. If you simply want to browse, you do not have to accept cookies from the Sites. Most browsers are defaulted to accept and maintain cookies. If you do not want websites to be able to use cookies, you can alter the configuration of your browser to not accept cookies.  Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites. Third party vendors, including Google, may use cookies to serve ads to you while you are using the Site based on your prior visits.  You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page. Should you decide, however, that you would like to create an account or purchase any Offerings with Superna and you have modified your browser settings not to accept cookies, you will need to re-set your browser to accept the cookies that we send it. Otherwise, you may not be able to register or obtain access to the Offerings. 

With or without cookies, our websites keep track of usage data, such as the source address from which a page request originates (i.e., your IP address, domain name), date and time of the page request, the referring website (if any), and other parameters in the URL (e.g., search criteria). We use this data to better understand website usage in the aggregate so that we know what areas of our Sites users prefer (e.g., based on the number of visits to those areas). This information is stored in log files and is used for aggregated and statistical reporting. It is not attributed to you as an individual.

Links to Other Sites: The Sites may provide links to third-party websites, such as those of our business partners, payment processors, and online advertisers. You should review their privacy policies to learn more about what, why, and how they collect and use personally identifiable information. 

Questions or Concerns: If you have questions or concerns regarding this statement, you should first contact us at privacy@superna.io. The mailing address for Superna USA, Inc. is 225 Cedar Hill St., STE. 200, Marlborough, MA 01752.

Changes to the Superna Privacy Policy:  Superna reserves the right to change this Privacy Policy from time to time. If we do make changes, the revised Privacy Policy will be posted on the Sites. 

NOTICE TO CHILDREN UNDER THE AGE OF 18 AND THEIR PARENTS OR LEGAL GUARDIANS:  THE SITES ARE INTENDED FOR ADULTS. WE DO NOT KNOWINGLY OR INTENTIONALLY COLLECT PERSONAL INFORMATION FROM ANYONE UNDER THE AGE OF 18. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION TO SUPERNA. IF YOU KNOW OF ANYONE UNDER THE AGE OF 18 WHO HAS PROVIDED US WITH INFORMATION, PLEASE CONTACT US IMMEDIATELY AND WE WILL REMOVE THE INFORMATION.

SPECIFIC PROVISIONS FOR CALIFORNIA RESIDENTS

This section of the Privacy Policy applies only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Information to provide notices and means to exercise rights.

California Notice of Collection

In the past 12 months, we or our service providers have collected the following categories of information enumerated in the CCPA in connection with the Sites and the Offerings:

• First and last name, billing, or other physical address (including street name, city/town, state/province, postal code, and country of origin), e-mail address, and telephone number, to the extent you are interacting with our Sites or ordering or using the Offerings;
• Information about Site and Offering usage;
• Any other identifier that permits Superna to make physical or online contact with you; 
• Internet activity, including history of visiting and interacting with our Sites, browser type, browser language and other information collected automatically by the Sites or Offerings; and
• Any other information you have chosen to provide to us through the Sites or the Offerings.

For more information on information we collect, including the sources we receive information from, review the sections above titled “Superna may collect your Personal Information when,” “The types of Personal Information collected may include (but are not limited to)” and “Cookies and Browser Information.” We collect and use these categories of Personal Information for the business purposes described in the “How does Superna use your information” section, including to provide, manage and improve our Sites. Superna does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA would be interpreted to include any of the activities described in the “Sharing of Your Personal Information” section, we will comply with applicable law as to such activity.

Right to Know and Delete

If you are a California resident, you have the right to delete Personal Information we have collected about you and you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following:

• Categories of Personal Information we have collected about you;
• Categories of sources from which the Personal Information was collected;
• Categories of Personal Information about you we disclosed for a business purpose or sold;
• Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose;
• Business or commercial purpose for collecting or selling the Personal Information; and
• Specific pieces of Personal Information we have collected about you.

To exercise any of these rights, please submit a request to us at privacy@superna.io. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. Please note that, in many instances, Superna does not collect types of Personal Information that enable us to identify you. As such, if we do not have information that permits us to verify your identity, we may deny your requests to know or delete. A request for access can be made by you only twice within a twelve (12) month period.

Right to Opt Out

Under the CCPA, you have the right to opt out of the sale of your Personal Information to third parties at any time. Superna does not “sell” your Personal Information as it is currently defined under the CCPA. You may contact us by emailing us at privacy@superna.io if you have any questions or concerns.

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

California Do-Not-Track Notice

We may collect information about your online activity while using our Sites and after you leave our Properties. Superna does not support Do Not Track signals, and therefore we do not respond to such signals. 

NOTICE TO INTERNATIONAL RESIDENTS: The Sites are primarily operated and managed on servers located and operated within the United States. In order to receive information about Superna or participate in the Offerings of Superna, you may be sending your PII outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your PII may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your PII. We are committed to protecting the privacy and confidentiality of PII when it is transferred. 

ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM:

Superna is headquartered in the Canada and has operations and service providers in Canada, the United States and throughout the world. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide levels of data protection equivalent to those in your country of residence. By using our Offerings, or otherwise interacting with us, regardless of where you live or where you provide information to us, you consent to our use and our service providers’ use of your Personal Information worldwide and to the transfer of your Personal Information to countries outside of your country of residence, including the United States. In certain circumstances, courts, regulatory agencies, law enforcement agencies, or security authorities in those other countries may be entitled to access your Personal Information.

Superna is aware of the July 16, 2020 ruling by the European Court of Justice invalidating the EU-US Privacy Shield Framework. Accordingly, Superna will take adequate measures designed to protect the transfer of Personal Information of individuals in the European Economic Area (EU Member States, Iceland, Liechtenstein, and Norway) (“EEA”), such as relying on the European Commission-approved Standard Contractual Clauses (“SCCs”) as a legal mechanism for such transfer, or other adequate transfer mechanism as required under relevant data protection laws, as well as additional safeguards, where appropriate. A copy of these clauses may be obtained by contacting us at the email address listed below. 

For transfers to or from the United Kingdom (“UK”), we make use of the SCCs, as adapted for the UK. For individuals located in the EEA or the UK, the terms “PII” and “Personal Information,” as used in this Privacy Policy, are equivalent to “personal data” under applicable European and UK data protection legislation.

If you are located in the EEA, the UK, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your Personal Information, as defined by the General Data Protection Regulation (“GDPR”), and this section applies to you.

Legal Basis for Processing 

When we process your Personal Information, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., providing the products or services you requested).
• When we have a legitimate interest in processing your Personal Information to operate our business or protect our interests (e.g., to provide, maintain, and improve our Offerings, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consent and track those who have opted out of non-administrative communications).
• When we have your consent to do so (e.g. when you opt-in to receive non-administrative communications from us). When consent is the legal basis for our processing of your Personal Information, you may withdraw such consent at any time.

Data Retention

We store Personal Information associated with your account for as long as your account remains active. In some cases, we retain Personal Information for longer if doing so is reasonably necessary to comply with our legal, regulatory, or other compliance obligations. We store other data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. 

Your Rights

For users in the European Union, according to the GDPR, you have the following statutory rights:

• Information. At the point where Personal Information is collected from the data subject, as defined by the GDPR, or obtained from another source, there is a requirement to inform the data subject about Superna’s use of that Personal Information and the rights of data subjects over it. Compliance with this right is provided within this Privacy Policy.
• Access. You have the right to obtain confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, all necessary information to make the process transparent. You also have the right to obtain a copy of your Personal Information being processed.
• Rectification. You have the right to require rectification of inaccurate data about you.
• Erasure. You have the right to ask for the deletion of your data in certain circumstances.
• Restrict processing. You have the right to restrict processing of data under certain specified circumstances.
• Data portability. You have the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your Personal Information.
• Object to processing. You have the right to ask us to stop using all or some of your Personal Information under certain specified circumstances. 
• Right to withdraw consent. When you have given your explicit consent for the processing of your data, you can withdraw it at any time without justification. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

If you would like to exercise your rights, please let us know by sending an email to privacy@superna.io.

You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.

This Privacy Policy was last amended 02/08/2024.