Privacy Policy — Surf (getsurfapp.com)

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. This privacy statement applies to all processing of personal data carried out by us in the context of providing our services and in particular on our website getsurfapp.com, the web application made available under that domain, and within external online presences such as our social media profiles (hereinafter collectively referred to as "online services").

Last Updated: April 22, 2026

Table of contents

• Preamble
• Controller
• Contact information of the data protection officer
• Contact information for privacy matters
• Overview of processing operations
• Legal Bases for the Processing
• Security Precautions
• Transmission of Personal Data
• Data Processing in Third Countries
• Erasure of data
• Business services
• Provision of online services and web hosting
• Registration, Login and User Account
• Single Sign-on Authentication
• Contact and Inquiry Management
• Newsletter and Electronic Communications
• Web Analysis, Monitoring and Optimization
• Use of AI Services
• Integrated Third-Party Services (HubSpot, Google APIs, Liveblocks)
• Profiles in Social Networks (Social Media)
• Plugins and embedded functions and content
• Changes and Updates to the Privacy Policy
• Rights of Data Subjects
• Terminology and Definitions

Controller

Superlist Software GmbH, c/o Pitch Software Joachimstr. 7, 10119 Berlin
E-mail: privacy@getsurfapp.com
Website: https://getsurfapp.com

Contact information for privacy matters

For all privacy-related inquiries, including requests to exercise your data subject rights, please contact:
E-mail: privacy@getsurfapp.com
A Data Processing Agreement (DPA) can be provided upon request via email to privacy@getsurfapp.com.

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.
Categories of Processed Data
• Inventory data (e.g. names, addresses).
• Payment Data (e.g. invoices, payment history).
• Contact data (e.g. e-mail, telephone numbers).
• Content data (e.g. text input, meeting notes, call preparation briefs).
• Contract data (e.g. contract object, duration, customer category).
• Usage data (e.g. pages visited, features used, access times, session recordings).
• Meta/communication data (e.g. device information, IP addresses).
• Third-party account data (e.g. HubSpot CRM data, Google Calendar and email metadata made available to us by you via authorised integrations).
Categories of Data Subjects
• Customers.
• Prospective customers.
• Communication partners.
• Users of our online services.
• Business and contractual partners.
• Third-party individuals whose data is contained in content provided to us by our customers (e.g. contacts in a customer's CRM or calendar).
Purposes of Processing
• Provision of contractual services and customer support.
• Contact requests and communication.
• Security measures.
• Direct marketing.
• Web analytics and product analytics.
• Office and organisational procedures.
• Managing and responding to inquiries.
• Server monitoring and error detection.
• Feedback.
• Profiles with user-related information.
• Authentication processes.
• Provision of our online services and usability.

Legal Bases for the Processing

In the following, you will find an overview of the legal bases of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If more specific legal bases are applicable in individual cases, we will inform you of these in this privacy policy.
• Consent (Article 6 (1) (a) GDPR) — The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
• Performance of a contract and prior requests (Article 6 (1) (b) GDPR) — Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Compliance with a legal obligation (Article 6 (1) (c) GDPR) — Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate Interests (Article 6 (1) (f) GDPR) — Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations apply to data protection in Germany. This includes in particular the Federal Data Protection Act (BDSG). The BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG). Data protection laws of the individual federal states may apply in addition.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.
SSL/TLS encryption (https): In order to protect your data transmitted via our online services in the best possible way, we use SSL/TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in our online services. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, on the basis of special guarantees, such as a contractual obligation through so-called Standard Contractual Clauses of the EU Commission, or where certifications (such as the EU-US Data Privacy Framework) or binding corporate rules justify the processing (Article 44 to 49 GDPR; information page of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en).

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose).
If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
In the context of our information on data processing, we may provide users with further information on the deletion and retention of data that is specific to the respective processing operation.
Termination: Personal data is kept as long as it is necessary to fulfil the purpose of the processing. Data will be deleted or anonymised as soon as it is no longer necessary to achieve the purpose. Upon termination of the service by a customer, customer content data will, in accordance with GDPR principles, be deleted within 30 days unless a longer retention is legally required. It is the responsibility of the customer to back up its data from the service in a timely manner; once deleted, the data cannot be restored.

Business services

We process the data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners") within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.
We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse and endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations.
Which data is necessary for the aforementioned purposes is communicated to the contractual partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colours or symbols such as asterisks), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving (e.g. as a rule 10 years for tax purposes). In the case of data disclosed to us by the contractual partner within the context of an assignment, we delete the data in accordance with the specifications of the assignment, in general after the end of the assignment.
If we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
Customer Account
Contractual partners can create a customer or user account. If the registration of a customer account is required, contractual partners will be informed of this as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent use of the customer account, we store the IP addresses of the contractual partners along with the access times, in order to be able to prove the registration and prevent any misuse of the customer account.
If customers have terminated their customer account, their data will be deleted with regard to the customer account, subject to its retention being required for legal reasons. It is the responsibility of the customer to secure their data upon termination of the customer account.
Software and Platform Services
We process the data of our users, registered users and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services (namely AI-powered customer-success briefings that combine calendar, CRM and related context into a concise pre-meeting summary) and on the basis of legitimate interests to ensure the security of our offer and to develop it further. The required details are identified as such within the context of the conclusion of the agreement, order or comparable contract and include the details required for the provision of services and invoicing as well as contact information in order to be able to hold any further consultations.
• Processed data types: Inventory data; Payment data; Contact data; Contract data; Content data (including meeting notes and generated briefs); Usage data; Meta/communication data; Third-party account data (from authorised integrations such as Google Calendar and HubSpot).
• Data subjects: Customers; Prospective customers; Business and contractual partners; Communication partners of our customers whose data appears in content our customers provide to us.
• Purposes of Processing: Provision of contractual services and customer support; Security measures; Contact requests and communication; Office and organisational procedures; Managing and responding to inquiries.
• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Provision of online services and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers they manage) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the framework of the provision of the hosting services may include all information relating to the users of our online services that is collected in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online services to browsers, and all entries made within our online services.
• Processed data types: Content data; Usage data; Meta/communication data.
• Data subjects: Users; Customers.
• Purposes of Processing: Provision of our online services and usability; Server monitoring and error detection; Provision of contractual services and customer support; Security measures.
• Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Collection of Access Data and Log Files: We, ourselves or our web hosting providers, collect data on the basis of each access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers. Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data, the further storage of which is necessary for evidence purposes, is excluded from deletion until the respective incident has been finally clarified.
Further information on processing methods, procedures and services used:
• Railway (application hosting): We use Railway to host and run the backend services that power Surf. Service Provider: Railway Corp., 2261 Market Street #4059, San Francisco, CA 94114, USA; Website: https://railway.com; Privacy Policy: https://railway.com/legal/privacy; Data Processing Agreement: https://railway.com/legal/dpa. Data transfers to the US are based on the EU Standard Contractual Clauses.
• Supabase (database and authentication): We use Supabase as our primary application database and authentication provider. Personal data of users and customer content (including contact details, account data and briefing content) are stored in Supabase. We use a Supabase environment with data hosted in the European Union where available. Service Provider: Supabase, Inc., 970 Toa Payoh North #07-04, Singapore 318992 / Supabase Pte. Ltd.; Website: https://supabase.com; Privacy Policy: https://supabase.com/privacy; Data Processing Agreement: https://supabase.com/legal/dpa; Security Measures: https://supabase.com/security. Where data is transferred to a third country, the transfer is based on the EU Standard Contractual Clauses.

Registration, Login and User Account

Users can create a user account. Within the scope of registration, the required mandatory information is communicated to users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name and an e-mail address; passwords are stored only in hashed form by our authentication provider).
Within the scope of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorised use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail of information relevant to their user account, such as technical changes.
• Processed data types: Inventory data; Contact data; Content data; Meta/communication data.
• Data subjects: Users.
• Purposes of Processing: Provision of contractual services and customer support; Security measures; Managing and responding to inquiries.
• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).
Further information:
• Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users.
• No obligation to retain data: It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract, subject to statutory retention obligations.

Single Sign-on Authentication

"Single Sign-On" or "Single Sign-On Authentication" are procedures that allow users to log in to our online services using a user account with a provider of Single Sign-On services (e.g. Google). The prerequisite for Single Sign-On Authentication is that users are registered with the respective Single Sign-On provider and enter the required access data in the form provided for this purpose, or are already logged in with the Single Sign-On provider and confirm the Single Sign-On login via the button.
Authentication takes place directly with the respective Single Sign-On provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in with the respective Single Sign-On provider under this user ID, together with an ID that cannot be used for other purposes (so-called "user handle"). Whether we receive further data depends solely on the Single Sign-On procedure used, the data releases selected as part of authentication, and which data users have released in the privacy or other settings of the user account with the Single Sign-On provider. Depending on the Single Sign-On provider and the user's choice, these can be different data, usually the e-mail address and the user name. The password entered with the Single Sign-On provider as part of the procedure is neither visible to us nor stored by us.
Should users decide to no longer want to use the link of their user account with the Single Sign-On provider for the Single Sign-On procedure, they must remove this link within their user account with the Single Sign-On provider. If users wish to delete their data from us, they must cancel their registration with us.
• Processed data types: Inventory data; Contact data.
• Data subjects: Users.
• Purposes of Processing: Provision of contractual services and customer support; Authentication processes.
• Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
• Google Single Sign-On: Authentication service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com; Privacy Policy: https://policies.google.com/privacy. Google is certified under the EU-US Data Privacy Framework.

Contact and Inquiry Management

When contacting us (e.g. via our contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
The response to contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre-)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.
• Processed data types: Inventory data; Contact data; Content data.
• Data subjects: Communication partners.
• Purposes of Processing: Contact requests and communication; Provision of contractual services and customer support.
• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Newsletter and Electronic Communications

We send newsletters, e-mails and other electronic communications (hereinafter referred to as "newsletters") only with the consent of the recipient or on the basis of a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and our company.
In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We may, however, ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further information if this is required for the purposes of the newsletter.
Double opt-in procedure: Registration to our newsletter takes place using a double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. Registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Changes to your data stored with the dispatch service provider are likewise logged.
Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of an obligation to permanently observe an objection, we reserve the right to store the e-mail address solely for this purpose in a blocklist.
Information on legal bases: The sending of the newsletter is based on the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing. Insofar as we engage a service provider for sending e-mails, this is done on the basis of our legitimate interests in efficient and secure dispatch. The registration procedure is recorded on the basis of our legitimate interests for the purpose of demonstrating that it has been conducted in accordance with the law.
Contents: Information about us, our services, product updates, promotions and offers.
• Processed data types: Inventory data; Contact data; Meta/communication data; Usage data.
• Data subjects: Communication partners.
• Purposes of Processing: Direct marketing (e.g. by e-mail).
• Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).
• Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter at the end of each newsletter, or you can otherwise use one of the contact options listed above, preferably e-mail to privacy@getsurfapp.com.
Measurement of opening rates and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file, which is retrieved from the mailing service provider's server when the newsletter is opened. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval, is first collected. This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. A separate objection to the performance measurement is unfortunately not possible; in such a case the entire newsletter subscription must be cancelled or objected to.
Further information on processing methods, procedures and services used:
• Resend (transactional e-mail): We use Resend to send transactional e-mails (e.g. account notifications, magic links, product messages) and, where applicable, e-mails containing briefing information prepared for our users. Service Provider: Resend (Resend Inc.), 2261 Market Street #5039, San Francisco, CA 94114, USA; Website: https://resend.com; Privacy Policy: https://resend.com/legal/privacy-policy; Data Processing Agreement: https://resend.com/legal/dpa. Data transfers to the US are based on the EU Standard Contractual Clauses.
• Loops (Loops.so) (marketing and lifecycle e-mail): We use Loops to manage and send newsletters, onboarding and lifecycle e-mails to subscribers and users. Service Provider: Loops, Inc. (Loops.so), San Francisco, CA, USA; Website: https://loops.so; Privacy Policy: https://loops.so/privacy; Data Processing Agreement: https://loops.so/dpa. Data transfers to the US are based on the EU Standard Contractual Clauses.

Web Analysis, Monitoring and Optimization

Web and product analytics are used to evaluate the visitor and usage behaviour within our online services and may include the behaviour, interests or — as pseudonymous values — demographic information of users. With the help of analytics we can recognise, for example, at which time our online services or their functions or contents are most frequently used, as well as which areas require optimisation.
Profiles, i.e. data aggregated for a usage process, may be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, pages visited and elements used there, features used within the product, as well as technical information such as the browser used, the computer system used and information on usage times. The IP addresses of the users are also stored. Where possible, we use IP masking or pseudonymisation.
In general, within the framework of web and product analytics, no clear identity data (such as e-mail addresses or names) is required to analyse usage; however, depending on configuration, product-analytics providers may associate events with the identifier of the logged-in user in order to improve the product for that user.
Information on legal basis: Where we ask users for their consent to the use of third-party providers (in particular where cookies or similar technologies are set that are not strictly necessary, or where session recording takes place), the legal basis of the processing is consent (Article 6 (1) (a) GDPR, § 25 (1) TDDDG). Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services; product improvement and error detection).
• Processed data types: Usage data; Meta/communication data; Content data (in the case of session recording: interactions with our product interface).
• Data subjects: Users.
• Purposes of Processing: Web and product analytics; Profiles with user-related information; Server monitoring and error detection; Provision of our online services and usability.
• Security measures: IP masking and pseudonymisation where technically feasible; configuration of session recording to mask personal content in form fields by default.
• Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
• PostHog (product analytics and session recording): We use PostHog to analyse how our product is used, to identify usability issues and to debug errors. PostHog collects events relating to pages viewed and interactions within our product, together with technical information (browser, operating system, device, approximate location derived from the IP address) and a pseudonymous user identifier. In addition, PostHog provides a session-recording feature that records a reconstruction of a user's interactions with our product interface (mouse movement, clicks, scrolling, page changes and, where not masked, the content of the pages displayed). We configure session recording with default masking of input fields and sensitive elements; nevertheless, content displayed on screen during a session may be captured. We use the PostHog EU Cloud offering; data collected via our PostHog instance is stored on servers located in the European Union (Frankfurt, Germany). Service Provider: PostHog Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA, with its UK entity PostHog UK Ltd., 338 Goswell Road, London EC1V 7LQ, United Kingdom; Website: https://posthog.com; Privacy Policy: https://posthog.com/privacy; Data Processing Agreement: https://posthog.com/dpa; Security: https://posthog.com/handbook/company/security. Although primary data storage takes place within the EU, limited access to the data by PostHog personnel from outside the EU/EEA cannot be excluded; such access is governed by the EU Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum. Legal basis: consent (Article 6 (1) (a) GDPR) for non-essential analytics and session recording; legitimate interests (Article 6 (1) (f) GDPR) for strictly necessary product telemetry. You can withdraw your consent at any time via our cookie/consent settings.

Use of AI Services

To provide the core functionality of Surf — in particular the generation of concise pre-meeting briefs, summaries of customer interactions and similar AI-assisted content — we use third-party AI services. When you use features that rely on these services, input content (which may include calendar information, emails, notes and CRM data that you or your organisation have made available to Surf) is transmitted to the respective AI provider for processing and a response is returned to us.
We have concluded a Data Processing Agreement with each AI provider. We have configured these services so that your data is not used by the AI provider to train or improve generalised AI or machine-learning models. Input and output data may be retained by the provider for a limited period solely for the purposes of providing the service, abuse monitoring and error detection, in accordance with the provider's terms.
• Processed data types: Content data (prompts, calendar items, emails, notes, CRM records, generated briefs); Inventory data; Contact data; Meta/communication data.
• Data subjects: Users; Communication partners of our users; Contacts and related individuals whose data is contained in content provided to us.
• Purposes of Processing: Provision of contractual services and customer support.
• Legal Basis: Performance of a contract (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR); where applicable, Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
• OpenAI (API): We use OpenAI's API to understand user inputs, to generate pre-meeting briefs and summaries and to power related AI features of Surf. If you are located in the European Economic Area ("EEA"), the United Kingdom or Switzerland, OpenAI Ireland Limited, 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland is the processor for your personal data. Otherwise, OpenAI, L.L.C., 3180 18th St, San Francisco, CA 94110, USA acts as the processor. Through our API usage and Data Processing Agreement with OpenAI, OpenAI does not use our business data (including prompts and outputs) submitted through the API to train its models. Website: https://openai.com; Privacy Policy: https://openai.com/enterprise-privacy; Data Processing Addendum: https://openai.com/policies/data-processing-addendum; Security: https://trust.openai.com. Data transfers to the US are based on the EU Standard Contractual Clauses; OpenAI LLC is also certified under the EU-US Data Privacy Framework.

Integrated Third-Party Services

To deliver our core service — connecting your calendar and CRM, pulling in recent activity, and generating a brief before every meeting — Surf integrates with a number of third-party services that you authorise on behalf of yourself or your organisation. In each case, Surf accesses the data only to the extent required to provide the requested functionality and in accordance with the scopes you have authorised. You can revoke these authorisations at any time within your account settings or directly with the respective provider.
• Processed data types: Inventory data; Contact data; Content data (e.g. calendar events, e-mail metadata and content where expressly authorised, CRM records such as contacts, companies, deals, notes, activities); Meta/communication data; Third-party account data.
• Data subjects: Users; Contacts, customers and other individuals whose data is stored by our users in the connected third-party systems.
• Purposes of Processing: Provision of contractual services and customer support; Feedback; Office and organisational procedures.
• Legal Basis: Performance of a contract (Article 6 (1) (b) GDPR); Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
• HubSpot (CRM integration and marketing operations): Our users can connect their HubSpot account to Surf so that we can read CRM data (contacts, companies, deals, notes, activities) needed to produce briefings, and write back notes and summaries to HubSpot. We also use HubSpot ourselves for our own marketing, sales and customer communications (e.g. managing our lead database and sending outbound messages). Service Provider: HubSpot, Inc., 2 Canal Park, Cambridge, MA 02141, USA, and HubSpot Ireland Limited, 1 Sir John Rogerson's Quay, Dublin 2, Ireland; Website: https://www.hubspot.com; Privacy Policy: https://legal.hubspot.com/privacy-policy; Data Processing Agreement: https://legal.hubspot.com/dpa. HubSpot is certified under the EU-US Data Privacy Framework; transfers to the US also rely on the EU Standard Contractual Clauses.
• Google Workspace APIs (Calendar, Gmail, Contacts): With the user's express authorisation (OAuth consent), we use Google Workspace APIs to read calendar entries, contact information and, where relevant to the requested functionality, e-mails, in order to prepare meeting briefs and surface relevant context. Google Workspace API data is not used to develop, improve or train generalised AI or ML models. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://workspace.google.com; Privacy Policy: https://policies.google.com/privacy; Google API Services User Data Policy: https://developers.google.com/terms/api-services-user-data-policy; Data Processing Agreement: https://workspace.google.com/terms/dpa_terms.html.
• Liveblocks (real-time collaboration): We use Liveblocks to provide real-time collaboration features within Surf (e.g. presence, cursors, shared editing of briefings and notes). Liveblocks processes connection metadata and the content of collaborative documents on our behalf. Service Provider: Liveblocks Inc., 2261 Market Street #4255, San Francisco, CA 94114, USA; Website: https://liveblocks.io; Privacy Policy: https://liveblocks.io/privacy; Data Processing Agreement: https://liveblocks.io/dpa. Data transfers to the US are based on the EU Standard Contractual Clauses.

Profiles in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's device, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data-protection declarations and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.
• Processed data types: Contact data; Content data; Usage data; Meta/communication data.
• Data subjects: Users.
• Purposes of Processing: Contact requests and communication; Feedback; Marketing.
• Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
• LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Data Processing Agreement: https://legal.linkedin.com/dpa; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• X (formerly Twitter): Social network; Service provider: Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, parent company: X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Policy: https://x.com/privacy; Settings: https://x.com/settings/personalization.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may, for example, be graphics, videos or fonts (hereinafter uniformly referred to as "Content").
The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents whose respective providers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. "Pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as be linked to such information from other sources.
Information on legal basis: If we ask users for their consent (e.g. in the context of a cookie banner consent), the legal basis for processing is this consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online services).
• Processed data types: Usage data; Meta/communication data; Inventory data; Contact data; Content data.
• Data subjects: Users.
• Purposes of Processing: Provision of our online services and usability; Profiles with user-related information.
• Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our privacy policy. We will adjust the privacy policy as changes in our data-processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Rights of Data Subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
• Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6 (1) GDPR, including profiling based on those provisions. Where personal data is processed for direct-marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right of withdrawal for consents: You have the right to revoke consents at any time with effect for the future.
• Right of access: You have the right to request confirmation as to whether the data in question is being processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
• Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of incorrect data concerning you.
• Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
• Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data-protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Terminology and Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations are intended above all for the purpose of comprehension. The terms are sorted alphabetically.
• Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Personal Data: "Personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
• Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content). Cookies and web beacons are often used for profiling purposes.
• Server monitoring and error detection: With the help of server monitoring and error detection, we ensure the availability and integrity of our online service and use the data processed in this process to technically optimise our online services. For this purpose, performance, utilisation and comparable technical values, which provide information about the stability and any conspicuous features of our online offering, are processed. In the event of errors and irregularities, individual requests from users of our online services are recorded in order to identify and eliminate sources of problems.
• Web Analytics: Web analytics serves the evaluation of visitor traffic to online services and can determine visitors' behaviour or interests in certain information, such as the content of websites. With the help of web analytics, website operators, for example, can recognise at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimise the content of the website to better meet the needs of their visitors. For purposes of web analytics, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.

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