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Privacy Policy

Last Updated: October 25, 2025 | Questions? Contact legal@surmado.com

Defined Terms: Key terms used in this Privacy Notice (Customer Inputs, Analysis Data, Outputs, Training Data) have the meanings set forth in our Terms of Service §2.

This Privacy Notice for Surmado, Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your Personal Information when you use our Services ("Services"), including when you:

  • Visit our website at https://www.surmado.com or any website of ours that links to this Privacy Notice
  • Use Surmado Signal, Scan, and Solutions. Surmado provides AI-powered business intelligence and strategic advisory tools for small and medium-sized businesses. Our core products include: Signal: Generates competitive intelligence reports by analyzing how various AI systems (like ChatGPT, Claude, Gemini) perceive and recommend your business compared to competitors. Solutions: An AI "board of directors" using multiple AI personalities to provide strategic analysis and recommendations for business decisions. Scan: An SEO audit tool analyzing website performance, technical SEO, and accessibility. We use customer-provided business information (like brand name, industry, competitors, optional financial data) and publicly available data (accessed via web search by some AI models) to generate insights. To generate these insights, we send data derived from your inputs to third-party AI Service Providers via API. Our policy is to process customer data securely and to minimize the transmission of identifiable or proprietary information where possible. However, the specific data handling and usage policies of these third-party AI providers are governed by their respective terms of service. We recommend users review the policies of the AI providers we utilize (currently including OpenAI, Anthropic, Google, DeepSeek, Together AI, X.AI, and Perplexity) for details on how they handle API data.
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your Personal Information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@surmado.com.


Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

Routing to AI Providers

To generate reports, we send the business content you put in analysis fields (e.g., brand/domain, competitors, product descriptions, high-level budgets/estimates) to third-party AI Service Providers via API. We do not send your account contact info (name, login email, full billing details) to AI Service Providers for this purpose. Please avoid Personal Information about individuals in free-text fields.

Training Data (de-identified)

We create de-identified and/or aggregated Training Data from Analysis Data and Outputs, and from Customer Inputs (after stripping direct Personal Identifiers but retaining business content), for internal model improvement, quality, safety, and research. We never attempt to re-identify. This use is a condition of the Services and is not offered on an opt-out basis.

What Personal Information Do We Process?

When you visit, use, or navigate our Services, we may process Personal Information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about Personal Information you disclose to us.

Do We Process Any Sensitive Personal Information?

We do not intentionally collect or require sensitive Personal Information (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or data concerning a person's sex life or sexual orientation) to provide our Services. However, users might voluntarily include information in free-text fields (like 'Brand Description' in Signal or 'Business Story' in Solutions) that could potentially imply sensitive details. We do not use any such inferred sensitive data for profiling or secondary purposes. For precise geolocation data collected automatically, users can typically disable this via device settings, although it may impact Service functionality. Learn more about information automatically collected.

Do We Collect Any Information from Third Parties?

We receive Personal Information from third parties (e.g., authentication providers like Clerk, payment processors like Stripe, and infrastructure providers) as needed to operate the Services. Learn more in Section 4.

How Do We Process Your Information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In What Situations and with Which Parties Do We Share Personal Information?

We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your Personal Information.

How Do We Keep Your Information Safe?

We have adequate organizational and technical processes and procedures in place to protect your Personal Information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What Are Your Rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your Personal Information. Learn more about your privacy rights.

How Do You Exercise Your Rights?

The easiest way to exercise your rights is by emailing us at legal@surmado.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.


Table of Contents

  1. What Information Do We Collect?
  2. How Do We Process Your Information?
  3. What Legal Bases Do We Rely on to Process Your Personal Information?
  4. When and with Whom Do We Share Your Personal Information?
  5. Do We Use Cookies and Other Tracking Technologies?
  6. Do We Offer Artificial Intelligence-Based Products?
  7. How Do We Handle Your Social Logins?
  8. Is Your Information Transferred Internationally?
  9. How Long Do We Keep Your Information?
  10. How Do We Keep Your Information Safe?
  11. Do We Collect Information from Minors?
  12. What Are Your Privacy Rights?
  13. Controls for Do-Not-Track Features
  14. Do United States Residents Have Specific Privacy Rights?
  15. Do We Make Updates to This Notice?
  16. How Can You Contact Us About This Notice?
  17. How Can You Review, Update, or Delete the Data We Collect from You?

1. What Information Do We Collect?

Personal Information You Disclose to Us

In Short: We collect Personal Information that you provide to us.

We collect Personal Information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You

The Personal Information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The Personal Information we collect may include the following:

  • Names
  • Email addresses
  • Usernames
  • Passwords
  • Billing addresses
  • Debit/credit card numbers

Sensitive Information

We do not intentionally collect or require sensitive Personal Information (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or data concerning a person's sex life or sexual orientation) to provide our Services. However, users might voluntarily include information in free-text fields (like 'Brand Description' in Signal or 'Business Story' in Solutions) that could potentially imply sensitive details. We do not use any such inferred sensitive data for profiling or secondary purposes. Please avoid including Personal Information about individuals in free-text analysis fields.

Payment Data

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

We use Stripe to process payments. We do not store your full credit card number or payment details on our own servers. Payment information is securely transmitted directly to Stripe, which is a PCI-compliant payment processor.

Social Media Login Data

We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

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

In Short: Some information is collected automatically when you visit our Services. This includes your Internet Protocol (IP) address and browser and device characteristics.

We automatically collect certain information when you visit, use, or navigate the 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, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.surmado.com/cookies.

Information We Collect Automatically

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 Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we derive approximate location from your IP address. We do not collect precise GPS location unless you explicitly grant device-level permission (not required for core Services). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. This applies if you connect a Google account for authentication (scope details are presented at connection time).


2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the Personal Information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

Training Data (de-identified)

We create de-identified and/or aggregated Training Data from Analysis Data and Outputs, and from Customer Inputs (after stripping direct Personal Identifiers but retaining business content), for internal model improvement, quality, safety, and research. We apply technical and organizational measures so the data cannot reasonably be used to identify you (CPRA §1798.140(h)) and is not reasonably likely to identify a person (GDPR Recital 26). We never attempt to re-identify. This use is a condition of the Services and is not offered on an opt-out basis.

We process your Personal Information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of Services to the user. We may process your information to provide you with the requested Service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested Service.
  • To send administrative information to you. We may process your information to send you details about our products and Services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
  • To create Training Data for Service Improvement. We may process de-identified and aggregated data derived from your use of the Services and your inputs (excluding Personal Data) to train our proprietary AI models, improve our analytical frameworks, enhance Service features, and conduct internal research, as further detailed in our Terms of Service and DPA.

3. What Legal Bases Do We Rely on to Process Your Personal Information?

In Short: We only process your Personal Information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with Services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If You Are Located in the EU or UK, This Section Applies to You

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your Personal Information. As such, we may rely on the following legal bases to process your Personal Information:

  • Consent: We may process your information if you have given us permission (i.e., consent) to use your Personal Information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Performance of a Contract: We may process your Personal Information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your Personal Information for some of the purposes described in order to:
    • Analyze how our Services are used so we can improve them to engage and retain users
    • Diagnose problems and/or prevent fraudulent activities
    • Understand how our users use our products and Services so we can improve user experience
  • Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If You Are Located in Canada, This Section Applies to You

We may process your information if you have given us specific permission (i.e., express consent) to use your Personal Information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations
  • We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and with Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers

We may share your data with third-party vendors, Service Providers, contractors, or agents ("third parties") who perform Services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your Personal Information. This means that they cannot do anything with your Personal Information unless we have instructed them to do it. They will also not share your Personal Information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Third Parties We Share Personal Information With

AI Service Providers (for generating analysis):

  • OpenAI
  • Anthropic
  • Google Cloud AI (including Gemini models)
  • X.AI (Grok models)
  • Perplexity AI
  • DeepSeek (served via Together AI - all processing occurs on U.S. infrastructure)
  • Meta AI (Llama 3 models, served via Together AI)
  • Together AI (hosting platform for open-source models)

Allow Users to Connect to Their Third-Party Accounts:

  • Google account

Cloud Computing Services:

  • Google Cloud

Functionality and Infrastructure Optimization:

  • Termly.io and Cloudflare

Invoice and Billing:

  • Stripe

User Account Registration and Authentication:

We use Clerk to provide authentication; Clerk receives only the data necessary to operate sign-in and account management.

Payments are processed by Stripe; Surmado never stores full payment card numbers.

Web and Mobile Analytics:

Analytics and Advertising Tools:

We use Plausible, a privacy-focused analytics tool that does not use cookies or store Personal Data by default. We may also use advertising technologies for targeted marketing; current partners are listed in our cookie consent banner. See Plausible's documentation and our Cookie Notice for details.

Other Situations

We also may need to share your Personal Information in the following situations:

Business Transfers: We may share or transfer your information 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.


5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic Site functions.

We also permit third parties and Service Providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and Service Providers use their technology to provide advertising about products and Services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Universal Opt-Out Signals (GPC)

We process browser/device-level opt-out signals such as Global Privacy Control (GPC) and other recognized universal opt-out mechanisms. When we receive a valid signal, we treat it as a request to opt out of "sale"/"sharing" (and targeted advertising where applicable) for that browser or device. If you are logged in, we also apply the preference to your account. Availability depends on your location and applicable law (currently CA, CO, CT, and OR beginning Jan 1, 2026). You can still manage preferences in our Settings.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.surmado.com/cookies.


6. Do We Offer Artificial Intelligence-Based Products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative Solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services. Routing is uniform for all customers; we do not offer provider exclusions, custom routing, or data-residency guarantees. See our Terms of Service §13C for details.

Use of AI Technologies

We provide the AI Products through third-party Service Providers ("AI Service Providers"), including Anthropic, OpenAI, DeepSeek, Perplexity, xAI, Google Cloud AI and Together AI. We may substitute substantially comparable providers; see our Sub-processor List at https://www.surmado.com/legal/subprocessors for current providers. As outlined in this Privacy Notice, your input, Output, and Personal Information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Note on DeepSeek: DeepSeek models are served via Together AI, a U.S.-based hosting platform. All processing occurs on U.S. infrastructure; no data is transmitted to the People's Republic of China.

Important Note on Third-Party AI Providers

To generate reports, we send the business content you put in analysis fields (e.g., brand/domain, competitors, product descriptions, high-level budgets/estimates) to third-party AI Service Providers via API. We do not send your account contact info (name, login email, full billing details) to AI Service Providers for this purpose. Please avoid Personal Information about individuals in free-text fields. Please review the privacy policies and terms and conditions of the listed AI Service Providers (https://www.surmado.com/legal/subprocessors) for further details.

Our AI Products

Our AI Products are designed for the following functions:

  • AI insights

How We Process Your Data Using AI

All Personal Information processed using our AI Products is handled in line with our Privacy Notice and our DPA.


7. How Do We Handle Your Social Logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your Personal Information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your Personal Information, and how you can set your privacy preferences on their Sites and apps.


8. Is Your Information Transferred Internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your Personal Information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), including facilities in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your Personal Information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses

We have implemented measures to protect your Personal Information, including by using the European Commission's Standard Contractual Clauses (and UK International Data Transfer Agreement or UK Addendum to the SCCs, as applicable) for transfers of Personal Information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all Personal Information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party Service Providers and partners and further details can be provided upon request.


9. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We retain Personal Information according to the following schedule based on data category:

  • Account Data (email, password, billing): While account is active (with no time limit for active accounts) + 3 years after account closure or last purchase for tax, audit, fraud prevention, and dispute resolution purposes.
  • Purchase-to-Account Linking Data: We temporarily store purchase records (session ID, email, amount) to link Stripe payments to user accounts. This data is automatically deleted immediately upon account creation, or after 90 days if no account is created, whichever occurs first.
  • Business Inputs (brand names, URLs, descriptions, strategic context): While account is active (with no time limit for active accounts) + 12 months after account closure for customer support and Services improvement. These may be converted to Training Data per our Terms of Service if properly de-identified.
  • Reports and Intelligence Packages: While account is active (with no time limit for active accounts) + 12 months after account closure for support and integration with other Surmado Services (e.g., Solutions intelligence tokens).
  • Training Data (de-identified): Retained for 24 months from creation, then automatically deleted, unless deletion is requested earlier per Section 12.

You may request deletion of your data at any time by emailing legal@surmado.com.

Upon verified deletion request, we will:

  1. Delete or irreversibly de-identify Personal Account Data from active systems within 30 days
  2. Overwrite backup copies within 35 days (standard backup rotation schedule)
  3. Invalidate all intelligence tokens (e.g., SIG-2025-10-XXXXX) preventing use with other Services
  4. Use reasonable efforts, including provenance records, to identify and remove derived Training Data that remains reasonably linkable to your account from active systems

We may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, 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 Information and isolate it from any further processing until deletion is possible. Training Data is retained for 24 months from creation as described above, unless earlier deletion is requested. Properly de-identified Training Data that cannot be reasonably linked back to the requesting user may persist in aggregated forms or within trained model artifacts where removal is technically infeasible or would require disproportionate effort.


10. How Do We Keep Your Information Safe?

In Short: We aim to protect your Personal Information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Services is at your own risk. You should only access the Services within a secure environment.


11. Do We Collect Information from Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such Personal Information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that Personal Information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at legal@surmado.com.


12. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your Personal Information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure; (iii) to restrict the processing of your Personal Information; (iv) if applicable, to Data Portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your Personal Information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing Your Consent

If we are relying on your consent to process your Personal Information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

Opting Out of Training Data Use

Creation and internal use of de-identified Training Data is a condition of the Services and is not offered on an opt-out basis. If you do not agree, you may request account deletion at legal@surmado.com; we will delete Customer Data from active systems as described in this Notice. Previously created de-identified Training Data may be retained.

Sole Proprietor Exception

Where a business name is a natural person's name (e.g., "Jane Smith Coaching"), we will treat that name as Personal Information for deletion and anonymization purposes within Training Data.

Financial Information Acknowledgment

If you provide financial estimates or projections to the Services (e.g., in Solutions), you acknowledge that such business-context information (excluding account credentials and billing details) will be shared with AI Service Providers to generate your analysis per Section 4. You waive confidentiality claims related to business information you voluntarily share with Surmado for analysis purposes.

Opting Out of Marketing and Promotional Communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you Service-related messages that are necessary for the administration and use of your account, to respond to Service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided.
  • Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and Similar Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or Services of our Services. For further information, please see our Cookie Notice: https://www.surmado.com/cookies.

If you have questions or comments about your privacy rights, you may email us at legal@surmado.com.


13. Controls for Do-Not-Track Features

Web browsers may send Global Privacy Control (GPC) or similar universal opt-out signals. We recognize and honor these signals where required by law (including CA, CO, CT, and OR beginning Jan 1, 2026). If we detect such a signal, we treat it as an opt-out of sale/share and targeted advertising for that browser or device and extend it to your account when authenticated. These browser signals apply only to advertising cookies/targeting; they do not alter our uniform AI Service Provider routing or our internal use of de-identified Training Data.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.


14. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the Personal Information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your Personal Information. You may also have the right to withdraw your consent to our processing of your Personal Information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of Personal Information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the Personal Information we collect from you. For a comprehensive inventory of all Personal Information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name YES
B. Personal Information as defined in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information YES
C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data NO
D. Commercial information Transaction information, purchase history, financial details, and payment information YES
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements YES
G. Geolocation data Device location YES
H. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities NO
I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us YES
J. Education Information Student records and directory information NO
K. Inferences drawn from collected Personal Information Inferences drawn from any of the collected Personal Information listed above to create a profile or summary about, for example, an individual's preferences and characteristics YES
L. Sensitive Personal Information NO

We may also collect other Personal Information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected Personal Information as needed to provide the Services or for:

  • Category A (Identifiers) - While account is active + 3 years after last purchase
  • Category B (Personal Information) - While account is active + 3 years after last purchase
  • Category F (Internet activity) - While account is active + 12 months
  • Category G (Geolocation data) - While account is active + 12 months

Sources of Personal Information

Learn more about the sources of Personal Information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your Personal Information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will Your Information Be Shared with Anyone Else?

We may disclose your Personal Information with our Service Providers pursuant to a written contract between us and each Service Provider. Learn more about how we disclose Personal Information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your Personal Information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your Personal Information.

We do not sell Personal Information in the traditional sense. However, we use or plan to use certain third-party analytics and advertising technologies that may constitute "sharing" or "targeted advertising" under state privacy laws. You can opt out via our cookie consent banner, Global Privacy Control (GPC) browser signals, or by contacting us at legal@surmado.com.

Our use of de-identified Training Data is performed with safeguards to prevent re-identification, consistent with our DPA. We care about data privacy and security. Please review our Privacy Policy: https://www.surmado.com/privacy. By using the Services, you agree to be bound by our Privacy Policy, which is incorporated into these Legal Terms:

Categories of Personal Information We Disclose for a Business or Commercial Purpose:

  • Category A. Identifiers
  • Category B. Personal Information as defined in the California Customer Records law
  • Category F. Internet or other electronic network activity information
  • Category G. Geolocation data

The categories of third parties to whom we disclosed Personal Information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your Personal Data
  • Right to access your Personal Data
  • Right to correct inaccuracies in your Personal Data
  • Right to request the deletion of your Personal Data
  • Right to obtain a copy of the Personal Data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your Personal Data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending Upon the State Where You Live, You May Also Have the Following Rights

  • Right to access the categories of Personal Data being processed (as permitted by applicable law, including the privacy law in Minnesota)
  • Right to obtain a list of the categories of third parties to which we have disclosed Personal Data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
  • Right to obtain a list of specific third parties to which we have disclosed Personal Data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
  • Right to obtain a list of third parties to which we have sold Personal Data (as permitted by applicable law, including the privacy law in Connecticut)
  • Right to review, understand, question, and depending on where you live, correct how Personal Data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
  • Right to limit use and disclosure of sensitive Personal Data (as permitted by applicable law, including the privacy law in California)
  • Right to opt out of the collection of sensitive data and Personal Data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

We honor Global Privacy Control (GPC) signals as an opt-out of sale/share where required by law. To exercise these rights, you can contact us by emailing us at legal@surmado.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Universal Opt-Out Mechanisms (UOOM)

Where required by law, we honor recognized UOOM signals (e.g., Global Privacy Control) as an opt out of sale/share and targeted advertising for that browser or device, and we extend the signal to your account when authenticated. In Colorado and Connecticut, this includes targeted advertising; Oregon will require recognition starting Jan 1, 2026.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use Personal Information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at legal@surmado.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"


15. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, 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 Notice frequently to be informed of how we are protecting your information.


16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at legal@surmado.com or contact us by post at:

Surmado, Inc.
1301 North Broadway
STE 32373
Los Angeles, CA 90012
United States

17. How Can You Review, Update, or Delete the Data We Collect from You?

You have the right to request access to the Personal Information we collect from you, details about how we have processed it, correct inaccuracies, or delete your Personal Information. You may also have the right to withdraw your consent to our processing of your Personal Information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your Personal Information, please email us at legal@surmado.com.


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