Effective Date: Jan 01, 2022
Your privacy is important to us. This Privacy Policy (“Policy”) explains how Supono Holdings LTD ("we", "us", or "Company") collects, uses, and protects your information when you use the Where is my phone Alexa Skill (the “Skill”). This Policy is in addition to the Terms of Service available at https://suponoholdings.com/terms. By using the Skill, you agree to both this Privacy Policy and the Terms of Service.
Your privacy is important to us. This Privacy Policy ("Policy") applies to services provided by Supono Holdings LTD Inc. ("we", "us", or "Company") and our website, mobile app, or other platform (collectively, the "Services"), explains what information we collect from users of our Services (a "user", "you", or "your"), including information that may be used to personally identify you ("Personal Information"), and how we use it. We encourage you to read the details below. This Policy applies to any visitor to or user of our Services. We will be the controller of your Personal Information provided to, or collected by or for, or processed in connection with, our Services.
We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by sending notice to the primary email address specified in your account or by a prominent notice on our website. Material changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check our website, including this privacy page, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Information is subject to the updated Policy.
What information do we collect?
We will only collect and process Personal Information about you where we have a lawful basis. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)) and "legitimate interests".
We collect information that you give us when you contact us, or otherwise access or use our Services, any information you voluntarily submit to us, and information regarding how you use the Services. Specifically, the foregoing includes:
Your internet protocol address (i.e., IP address) and, if you access the Services from a mobile application, your unique mobile device ID number and non-email authentication.
Your name, email address, zip code, current location, telephone number, profile picture, your responses, including audio communications recorded by us or our third-party technology providers (where permitted by law), to in-game questions, such as Alexa surveys, or other surveys that we may ask you to complete for research purposes or to help direct Company activities, the contact information of your representative, your social media account information and information shared with us via your social media accounts.
Details of any financial transactions you participate in on the Services, including the amount, currency, and method of payment.
Browser and device information and information collected through technologies such as cookies, pixel tags, web beacons and other technologies.
If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
How do we use the information we collect?
We use the information we collect to:
Develop, operate, improve, maintain, protect, and deliver the Services and your overall user experience, including by means of training and refining artificial intelligence and machine learning models;
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
To link or combine user information with other Personal Information;
To compare and verify information for accuracy and update our records;
Email, text, message, or otherwise contact you with information and updates about us and the Services;
To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Analyze how you use the Services with tools such as Google Analytics and other tools to help us understand traffic patterns and know if there are problems with the Services;
Create targeted advertising to promote the Services and engage our users;
Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Supono Holdings LTD and others;
Facilitate business transactions and reorganizations impacting the structure of our business;
Comply with contractual and legal obligations and requirements;
Fulfill any other purpose for which you provide your Personal Information, or for which you have otherwise consented.
Do we share your Personal Information?
We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized.To help us do our work, we may provide limited access to some of your Personal Information to the following third parties:
Partners: Sometimes we collaborate with other organizations to deliver the Services. In these cases, we may share your name, contact information and other details you provided when making an account with our partners.
Service Providers: We work with a wide range of third-party service providers, notably our database administrators, cloud computing services, audio recording providers, artificial intelligence and machine learning model providers, advertising services, data analysts, application service providers, bulk SMS services, and other non-governmental organizations. We may share Personal Information with these service providers in the course of their performance of services on our behalf.
Payment Processors: We work with payment processors such as PayPal, Stripe, Google Pay to help process credit card transactions and other payment methods made through the Services. These payment processors will store certain information about you. Please refer to their privacy policies to learn more about how they use your Personal Information.
We may store information such as names, email addresses, telephone number, profile picture, user survey responses, third party social media account information (e.g. Facebook, Google), and zip code in our databases or any information that is necessary to enable us to operate effectively and deliver our services to you. We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; and to protect the rights or property of Company. In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.
Protection of Company and Others
We will also share Personal Information with companies, organizations, or individuals outside of Company if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, or protect against harm our legal rights or safety.
How do we use Tracking Technologies?
A "cookie" is a small file placed on your hard drive by some of our web pages. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies are commonly used at most major transactional websites in much the same way we use them in our Services.
You may delete and block all cookies from our Services, but parts of the Services may not work. We want to be open about our cookie use.
Even if you are only browsing the Services, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services) is automatically collected about you. This information will be collected every time you access the Services and it will be used for the purposes outlined in this Privacy Policy.
You can reduce the information cookies collect from your device. An easy way of doing this is often to change the settings in your browser. If you do that you should know that (a) your use of the Services may be adversely affected (and possibly entirely prevented), (b) your experience of this and other sites that use cookies to enhance or personalize your experience may be adversely affected, and (c) you may not be presented with advertising that reflects the way that you use our and other sites. You can find out how to make these changes to your browser at this site: www.allaboutcookies.org/manage-cookies/. Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as you access our Services. By using the Services you consent to this, unless you change your browser settings.
How do we secure your Personal Information?
We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. The safety and security of your Personal Information also depends on you. If you have an account with us, you are responsible for keeping your membership details confidential. Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using the Services, you acknowledge that you understand and agree to assume these risks.
We retain your Personal Information while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of the Services.
Your choices regarding Information
You have several choices regarding the use of Personal Information on the Services:
Changing or Deleting Your Personal Information. All users may review, update, correct or delete the Personal Information furnished by a user in their user account (including any imported contacts) by contacting us at support@suponoholdings.com or by accessing your user account. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your Personal Information, then your user account may become deactivated. If you wish to cancel your account, you may do so through your account page, and any Personal Information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Download or Access Your Personal Information. You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine readable form by emailing us at support@suponoholdings.com.
Opting Out of Email Communications. We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Company features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us at support@suponoholdings.com to opt out. Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Service or Privacy Policy.
Links to Third Party Websites
We may provide links to other websites. We have no control over these websites and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third party websites.
By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites.
How we respond to Do Not Track signals
Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com
Children Under 16
The Services are not directed to individuals who are under the age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at support@suponoholdings.com and the information will be deleted.
Third Party Direct Marketing
We currently do not share Personal Information with third parties for their direct marketing purposes without your consent.
A Note to Users Outside the United States
Our Company is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.
Contact Us
If you have any questions about this Policy, your Personal Information, or the Services, you can contact support@suponoholdings.com.
NOTE: This Privacy Policy is designed to comply with Amazon's requirements for Alexa Skills and adheres to Amazon's policies on data collection, storage, and use. If any conflict arises between this policy and Amazon's privacy terms, Amazon's terms shall take precedence.
This Policy applies to the Personal Information collected by our Skill on Amazon devices. We collect only the information necessary to operate the Skill, which includes your phone number (and a generated One-Time Password for identity verification) and minimal payment attribution data from Amazon to verify your subscription status.
We use your information solely to provide the service. We retain your Personal Information only as long as necessary to provide the service. If you do not use the Skill for 3 months after your subscription ends, we delete your Personal Information from our active databases. If backups exist, they are permanently removed within 30 days per our data retention policy. You may also request deletion at any time by contacting us at info@suponoholdings.com.
By using our Skill, you consent to the collection and use of your Personal Information as described in this Policy. We reserve the right to update this Policy at any time; material changes will take effect 30 days after notice is provided. Your continued use of the Skill after such changes constitutes your acceptance of the updated Policy.
We collect Personal Information only when necessary to provide the service. Specifically, we collect:
Skill-Specific Information: Your phone number and a generated One-Time Password (OTP) used solely for verifying your identity and enabling the "Where is my phone" feature.
Payment Attribution Information: The minimal data provided by Amazon necessary to determine your subscription status.
Technical and Location Information: user IP address, User-Agent, and location data (when user provides consent) to improve service functionality and enhance user experience.
Account and Identification Information: We generate and store a unique user ID to manage user account and service interactions.
The information we collect is used exclusively for operating the Skill. Specifically, we use your Personal Information to:
Enable you to register and verify your phone number so that you can use the "Where is my phone" feature.
Call your phone number to locate your phone using our Alexa skill, "Where is my Phone."
Determine your subscription status (for example, to check whether you are subscribed to our premium plan for unlimited calls).
Send you essential communications such as confirmations, technical notifications, and service updates.
We do not use your information for any purposes beyond providing and maintaining the Skill.
We do not sell or rent your Personal Information. We share your data only in limited circumstances, including:
Service Providers: Trusted third-party providers (for example, Twilio, which we use to send SMS messages and make phone calls). Twilio may temporarily retain call and SMS logs for fraud prevention and operational purposes. You can review Twilio’s retention policies. Please review: Twilio’s Terms of Service and Twilio’s Privacy Policy for more details.
Payment Processors: If you subscribe to our premium plan, payment processors (via Amazon) handle your transaction data in accordance with their privacy policies.
Legal Requirements: We may disclose your Personal Information if required by law or in response to a valid legal request.
In the event of a merger, acquisition, or reorganization, your Personal Information may be transferred to the successor entity. We will provide notice and, if necessary, seek your consent for any material changes.
We store your Personal Information only for as long as necessary to operate the Skill and comply with legal requirements.
Active Data Retention: If you use the Skill regularly, we keep your data to provide uninterrupted service.
Inactive User Data: If you do not use the Skill for 3 months after your subscription ends, your Personal Information is deleted from our active databases.
Backup Retention: If backups exist, they are permanently removed within 30 days in accordance with our data retention policy.
User-Initiated Deletion: You may request deletion of your Personal Information at any time by contacting info@suponoholdings.com. Once processed, your data will be permanently erased from our active systems and backups within 30 days.
We implement strict access controls to ensure that only authorized personnel can manage stored information. Our storage policies are regularly reviewed to comply with industry standards and legal requirements.
No cookies or tracking is being done in this skill.
We take your data security seriously. Our security measures include:
Encryption of sensitive data using industry-standard protocols;
Firewalls and secure socket layer (SSL) technology during data transmission;
Strict access controls to ensure that only authorized personnel can access your data.
Although we strive to protect your data, no system is completely secure. You are responsible for protecting your account credentials by not sharing your password and logging out after each use. By using our Skill, you acknowledge the inherent risks associated with data transmission and storage.
We retain your Personal Information only for as long as it is necessary to provide the service. When you are no longer active, we cease storing your data.
We do not store or record any voice interactions beyond what is necessary to process your requests in real time. All voice data is processed on the fly and is not retained after the interaction.
You have the right to control your Personal Information. If you are located in a jurisdiction with strict data protection laws, you have additional rights, including the right to access, correct, or delete your data. These rights include:
Access or Update: Request to view or update your Personal Information by contacting us at info@suponoholdings.com.
Deletion: Request the deletion of your Personal Information by contacting us at info@suponoholdings.com, subject to legal requirements.
Data Portability: Request a copy of your Personal Information in a machine-readable format.
Opt-Out of Marketing: Unsubscribe from promotional communications by using the unsubscribe link in our emails or contacting us directly.
GDPR Rights: If you are located in the European Union, you have rights under the General Data Protection Regulation (GDPR), including the right to access, rectify, and erase your Personal Information. Please contact us to exercise these rights.
Your Personal Information may be transferred to, stored, and processed in countries with data protection laws that differ from those in your country of residence. By using our Skill, you consent to such international transfers.
In addition to the information you provide, our Skill receives minimal payment attribution data from Amazon necessary to verify your subscription status. This data is used solely for that purpose and is handled in accordance with Amazon’s privacy policies.
Some devices and browsers send a “Do Not Track” (DNT) signal. Please note that we do not alter our data collection practices in response to DNT signals, as our Skill does not use behavioral tracking for targeted advertising. For more information on DNT, please visit allaboutdnt.com.
Our Skill is not intended for individuals under the age of 16, and we do not knowingly collect Personal Information from children under 16. If you believe we have inadvertently collected data from a child under 16, please contact us immediately at info@suponoholdings.comso that we can promptly remove the data.
We do not share your Personal Information with third parties for their direct marketing purposes without your explicit consent.
If you have any questions or concerns regarding this Privacy Policy or our data practices, please contact us at:
Email: info@suponoholdings.com
Website: https://suponoholdings.com