Privacy Policy for Surgent

Last Updated: 9th January 2025

1. Introduction

Welcome to Surgent!

Surgent ("us", "we", or "our") operates the Surgent AI-powered text generation platform and related services (collectively referred to as the "Services"). This Privacy Policy governs your use of our Services and explains how we collect, use, safeguard, and disclose information resulting from your interaction with our platform.

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you are using the Services on behalf of a company or legal entity, additional terms may apply as outlined in our Platform Services Agreement.

This Privacy Policy is intended to comply with applicable privacy laws, including the EU General Data Protection Regulation (GDPR), the UK Data Protection Act, the California Consumer Privacy Act (CCPA/CPRA), and other relevant international regulations.

2. Definitions

Service: The AI-powered platform operated by Surgent, including related products, APIs, and websites.
Personal Data: Any information about an individual who can be identified directly or indirectly.
Usage Data: Data collected automatically through the use of our Services, including IP address, browser type, and interaction logs.
Cookies: Small files stored on your device that help us improve user experience and track certain information.
Data Controller: Surgent, responsible for determining the purposes and means of processing personal data.
Data Processor: Third-party service providers who process data on behalf of Surgent.
Sensitive Personal Data: A subcategory of personal data that includes information such as health, racial or ethnic origin, political opinions, religious beliefs, or sexual orientation, processed only where required by law or with explicit consent.

3. Why We Collect Your Information

We collect information for the following purposes:

To provide and maintain our Services
To notify you of changes and updates
To offer customer support and respond to inquiries
To enhance user experience by improving the Services
To monitor and analyze usage patterns
To ensure compliance with legal obligations
To protect our systems and prevent fraud or misuse

4. Personal Data We Collect

Categories of Personal Data:

Personal Identification Data: Name, email address, phone number, and postal address
Account Information: Username, password, and any profile details provided
Payment Information: Billing details and payment method (processed securely by third-party payment providers)
Usage Data: IP address, browser type, session duration, and pages visited
Cookies and Tracking Data: Details of your interaction with our Services
Marketing Preferences: Information you provide when subscribing to newsletters or promotional materials

5. Information Collected from Other Sources

We may collect additional information from third-party sources, including:

Integrations: Data from external services you connect to our platform
Partners: Information provided by marketing and data enrichment partners
Social Logins: If you log in using a third-party service (e.g., Google), we may receive profile information such as name and email address as authorized by your settings

6. How We Use Personal Data

We process your data for:

Providing Services: Ensuring the platform functions effectively
Account Management: Managing your registration and access
Service Improvement: Enhancing and optimizing our platform
Communication: Sending updates, promotional materials, and responding to queries
Security: Detecting and preventing security threats
Legal Compliance: Fulfilling legal obligations and protecting our rights
Personalized Content: Offering suggestions or features tailored to your usage

7. Legal Basis for Processing Personal Data

Under GDPR, we rely on the following legal bases:

Consent: When you provide explicit consent
Contractual Necessity: When data is needed to perform our contract with you
Legal Obligation: When processing is required to comply with the law
Legitimate Interests: For purposes such as improving our services, provided your rights are not overridden. You have the right to object to processing based on our legitimate interests at any time.

8. User Rights

If you are an EU or EEA resident, you have the following rights under GDPR:

Access: Request a copy of your personal data
Rectification: Request correction of inaccurate data
Erasure: Request deletion of your data
Restriction: Request limited processing of your data
Portability: Receive your data in a machine-readable format
Objection: Object to processing for direct marketing or legitimate interests
Withdrawal of Consent: Withdraw consent at any time

To exercise any of these rights, please contact us at support@surgent.ai.

To ensure security, we may request verification of your identity before processing your request.

If you are a resident of another jurisdiction with privacy laws (e.g., Brazil, Australia, or certain U.S. states), you may have similar rights under local laws. Please contact us to learn more.

We may share your personal data in the following cases:

Service Providers: With vendors providing analytics, hosting, and customer support
Business Transfers: If Surgent is involved in a merger, acquisition, or asset sale
Legal Requirements: When required by law or to protect our legal rights
With your consent: We may share data for purposes not listed here if you have provided explicit permission.

10. Data Retention

We retain personal data for as long as necessary to provide our Services and comply with legal obligations. Usage data is retained for shorter periods unless used for security or service improvement. When we no longer need your data, we securely delete or anonymize it.

11. Data Security

We implement commercially reasonable measures to protect your data. However, no method of transmission or storage is 100% secure. You acknowledge that there are inherent risks in using online services.

If we experience a data breach affecting your personal data, we will notify you and the appropriate authorities where legally required.

12. International Data Transfers

Your information may be transferred to and processed in countries outside of your jurisdiction, including the United States.

We rely on Standard Contractual Clauses (SCCs) approved by the European Commission and other lawful mechanisms to ensure adequate protection of your data when transferred outside the EEA.

Where applicable, we also assess data transfer risks and implement supplementary measures in line with Schrems II guidance.

13. Cookies and Tracking Technologies

We use cookies for various purposes:

Session Cookies: To maintain your session
Preference Cookies: To remember your preferences
Analytics Cookies: To improve our services
Advertising Cookies: To deliver relevant ads

We use a cookie consent banner to obtain your explicit consent before placing cookies that are not strictly necessary. You can change or withdraw your consent at any time through your cookie settings or browser preferences.

For more details, see our Cookie Policy which supplements this Privacy Policy.

14. Children's Privacy

Our Services are not intended for use by individuals under 18. If we learn that we have collected data from a minor without parental consent, we will take steps to delete such information.

Our Services are not directed at individuals under the age of digital consent in their jurisdiction (e.g., 13 in the U.S., up to 16 in the EU).

15. Payments

Payment processing is handled by third-party providers such as Stripe and PayPal. We do not store your payment details.

Please review the privacy policies of those providers to understand how your payment data is processed.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of significant changes by email or a prominent notice on our platform. We encourage you to review this Privacy Policy regularly to stay informed.

17. Contact Information

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

Email: support@surgent.ai

For legal or regulatory matters, you may also contact us at legal@surgent.ai

18. Dispute Resolution and Complaint Mechanisms

Users in the EU and EEA have the right to lodge a complaint with their local data protection authority.

In Denmark, this is Datatilsynet: www.datatilsynet.dk

If you are based in the UK, you may contact the Information Commissioner's Office (ICO): www.ico.org.uk

For other disputes, please contact us directly to seek resolution.

19. Additional Information for California Residents (CCPA/CPRA Compliance)

If you are a California resident, you have rights under CCPA/CPRA, including:

Right to Know: What personal data we collect and how we use it
Right to Delete: Request deletion of your data
Right to Opt-Out: Opt out of the sale of personal information

To exercise your rights, contact us at support@surgent.ai

We do not sell personal data in exchange for money, but you may opt out of sharing that constitutes a "sale" under CCPA.

20. Additional Information for Other US States

If you are a resident of states with specific privacy laws (e.g., Virginia, Colorado), you may have additional rights. Please contact us for further information.

Where required by law, we will honor opt-out signals such as Global Privacy Control (GPC).

21. Change History

We keep a record of significant updates to this Privacy Policy. To view past versions, please contact us at support@surgent.ai.

You may also request a summary of changes made since your last acceptance of this policy.

22. Governing Law

This Privacy Policy is governed by the laws of England and Wales. Any disputes arising under this policy will be resolved in the courts of London, United Kingdom.