Privacy Policy
NdotLight Co., Ltd.
Privacy Policy
Privacy Policy
Last updated: May 26th, 2025
Last updated: May 26th, 2025
Last updated: May 26th, 2025
Last updated: May 26th, 2025
This Privacy Policy describes how NdotLight Co., Ltd. ("NdotLight," “Surfee,” "we", “us,” or "our") processes personal information that we collect through our digital or online properties or services (including Surfee) that link to this Privacy Policy (including as applicable, our websites (including https://www.surfee.io/) social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)).
This Privacy Policy does not apply to information that we process as a processor or service provider on behalf of our educational customers (such as schools and districts) (our “Educational Customers”) while providing our Services to them. Our use of information that we process on behalf of our Educational Customers may be governed by our agreements with such customers, and our Educational Customers may also have their own privacy policies that govern their users’ personal information that is collected in connection with their use of our Services — such privacy policies will govern how each Educational Customer processes personal information and explain any rights their users may have to such personal information. If you have questions or concerns regarding your personal information that we process on behalf of an Educational Customer, please see the applicable Educational Customer’s privacy policy or direct your concerns to that customer.
1. Personal information we collect
1. Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
Demographic data, such as your city, state, country of residence, postal code, age, and gender.
Profile data, such as the username and password that you may set to establish an online account on the Service, redemption code, photograph or picture, links to your profiles on social networks.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Payment data needed to complete transactions, including payment card information or bank account number. This information may be processed by our payment vendors, such as Stripe.
User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
Public sources, such as social media platforms and other publicly available sources.
Private sources, such as data providers, social media platforms and data licensors.
Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
Marketing partners, such as joint marketing partners and event co-sponsors.
Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
Service providers. We may combine personal information we receive from or generate about you with information we receive from service providers that collect or provide personal information to us in connection with the work they do on our behalf.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data such ****as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
Data about others. We may offer features that allow users to provide the personal information of others, and we may collect contact details about these individuals, including for the purposes of completing an in-person tour. Please do not share their contact details with us unless you have their permission to do so.
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
Demographic data, such as your city, state, country of residence, postal code, age, and gender.
Profile data, such as the username and password that you may set to establish an online account on the Service, redemption code, photograph or picture, links to your profiles on social networks.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Payment data needed to complete transactions, including payment card information or bank account number. This information may be processed by our payment vendors, such as Stripe.
User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
Public sources, such as social media platforms and other publicly available sources.
Private sources, such as data providers, social media platforms and data licensors.
Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
Marketing partners, such as joint marketing partners and event co-sponsors.
Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
Service providers. We may combine personal information we receive from or generate about you with information we receive from service providers that collect or provide personal information to us in connection with the work they do on our behalf.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data such ****as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
Data about others. We may offer features that allow users to provide the personal information of others, and we may collect contact details about these individuals, including for the purposes of completing an in-person tour. Please do not share their contact details with us unless you have their permission to do so.
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
Demographic data, such as your city, state, country of residence, postal code, age, and gender.
Profile data, such as the username and password that you may set to establish an online account on the Service, redemption code, photograph or picture, links to your profiles on social networks.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Payment data needed to complete transactions, including payment card information or bank account number. This information may be processed by our payment vendors, such as Stripe.
User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
Public sources, such as social media platforms and other publicly available sources.
Private sources, such as data providers, social media platforms and data licensors.
Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
Marketing partners, such as joint marketing partners and event co-sponsors.
Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
Service providers. We may combine personal information we receive from or generate about you with information we receive from service providers that collect or provide personal information to us in connection with the work they do on our behalf.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data such ****as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
Data about others. We may offer features that allow users to provide the personal information of others, and we may collect contact details about these individuals, including for the purposes of completing an in-person tour. Please do not share their contact details with us unless you have their permission to do so.
2. How we use your personal information
2. How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
provide, operate and improve the Service and our business;
establish and maintain your user profile on the Service;
facilitate your invitations to friends who you want to invite to join the Service;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.
Service personalization. We may use your personal information to personalize the Service for you, which may include using your personal information to:
understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate the Service.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:
comply with applicable laws (including without limitation identity verification), lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
provide, operate and improve the Service and our business;
establish and maintain your user profile on the Service;
facilitate your invitations to friends who you want to invite to join the Service;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.
Service personalization. We may use your personal information to personalize the Service for you, which may include using your personal information to:
understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate the Service.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:
comply with applicable laws (including without limitation identity verification), lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
provide, operate and improve the Service and our business;
establish and maintain your user profile on the Service;
facilitate your invitations to friends who you want to invite to join the Service;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.
Service personalization. We may use your personal information to personalize the Service for you, which may include using your personal information to:
understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate the Service.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:
comply with applicable laws (including without limitation identity verification), lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
3. How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties ****that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Payment processors. Any payment card information you use to book a tour on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers, such as StabilityAI and Blackforestlabs, Salesforce to power certain aspects of the Service, including for content creation. These providers may use your personal information as outlined in their respective privacy policies which are available at https://stability.ai/privacy-policy and https://blackforestlabs.ai/privacy-policy/ and https://www.salesforce.com/company/legal/privacy/.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Business and marketing partners. Third parties ****with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in NdotLight, financing of NdotLight, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of NdotLight as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Your profile and other user-generated content data (except for messages) are visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties ****that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Payment processors. Any payment card information you use to book a tour on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers, such as StabilityAI and Blackforestlabs, Salesforce to power certain aspects of the Service, including for content creation. These providers may use your personal information as outlined in their respective privacy policies which are available at https://stability.ai/privacy-policy and https://blackforestlabs.ai/privacy-policy/ and https://www.salesforce.com/company/legal/privacy/.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Business and marketing partners. Third parties ****with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in NdotLight, financing of NdotLight, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of NdotLight as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Your profile and other user-generated content data (except for messages) are visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties ****that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Payment processors. Any payment card information you use to book a tour on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers, such as StabilityAI and Blackforestlabs, Salesforce to power certain aspects of the Service, including for content creation. These providers may use your personal information as outlined in their respective privacy policies which are available at https://stability.ai/privacy-policy and https://blackforestlabs.ai/privacy-policy/ and https://www.salesforce.com/company/legal/privacy/.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Business and marketing partners. Third parties ****with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in NdotLight, financing of NdotLight, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of NdotLight as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Your profile and other user-generated content data (except for messages) are visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
4. Your choices
In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.
Access, update, and delete certain of your information. If you have registered for an account with us through the Service, you may be able to access, update and delete certain personal information through account features.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Policy.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
Google: https://adssettings.google.com/
Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.
Access, update, and delete certain of your information. If you have registered for an account with us through the Service, you may be able to access, update and delete certain personal information through account features.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Policy.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
Google: https://adssettings.google.com/
Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.
Access, update, and delete certain of your information. If you have registered for an account with us through the Service, you may be able to access, update and delete certain personal information through account features.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Policy.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
Google: https://adssettings.google.com/
Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
5. Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
6. Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
7. International data transfer
We are headquartered in South Korea and may use service providers that operate in other countries. Your personal information may be transferred to South Korea, the United States, or other locations where privacy laws may not be as protective as those in your state, province, or country.
We are headquartered in South Korea and may use service providers that operate in other countries. Your personal information may be transferred to South Korea, the United States, or other locations where privacy laws may not be as protective as those in your state, province, or country.
We are headquartered in South Korea and may use service providers that operate in other countries. Your personal information may be transferred to South Korea, the United States, or other locations where privacy laws may not be as protective as those in your state, province, or country.
8. Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
9. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
10. How to contact us
Email: support@surfee.io
Phone: +82-70-7537-0585
Email: support@surfee.io
Phone: +82-70-7537-0585
Email: support@surfee.io
Phone: +82-70-7537-0585
11. State privacy rights notice
Additional information for California residents. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to contact@ndotlight.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Additional information for California residents. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to contact@ndotlight.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Additional information for California residents. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to contact@ndotlight.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
12. Notice to European users
3. Termination of
Service Usage Agreement
General
Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”) Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.
Controller. NdotLight is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can contact them directly should you wish:
Our Representative in the EU.
Our EU representative appointed under the EU GDPR is NdotLight.
You can contact them:
• By email to: privacy@surfee.io
• By postal mail to: 838 Walker Road, Suite 21-2, Dover, Delaware 19904
Our Representative in the UK.
Our UK representative appointed under the UK GDPR is NdotLight.
You can contact them:
• By email to: privacy@surfee.io
• By postal mail to: 838 Walker Road, Suite 21-2, Dover, Delaware 19904
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.
General
Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”) Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.
Controller. NdotLight is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can contact them directly should you wish:
Our Representative in the EU.
Our EU representative appointed under the EU GDPR is NdotLight.
You can contact them:
• By email to: privacy@surfee.io
• By postal mail to: 838 Walker Road, Suite 21-2, Dover, Delaware 19904
Our Representative in the UK.
Our UK representative appointed under the UK GDPR is NdotLight.
You can contact them:
• By email to: privacy@surfee.io
• By postal mail to: 838 Walker Road, Suite 21-2, Dover, Delaware 19904
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.
General
Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”) Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.
Controller. NdotLight is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can contact them directly should you wish:
Our Representative in the EU.
Our EU representative appointed under the EU GDPR is NdotLight.
You can contact them:
• By email to: privacy@surfee.io
• By postal mail to: 838 Walker Road, Suite 21-2, Dover, Delaware 19904
Our Representative in the UK.
Our UK representative appointed under the UK GDPR is NdotLight.
You can contact them:
• By email to: privacy@surfee.io
• By postal mail to: 838 Walker Road, Suite 21-2, Dover, Delaware 19904
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the ‘Compliance and protection’ purposes outlined above.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information that we have collected about you, we will either delete or anonymize it 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other information
No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.
No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.
Your additional rights
General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision.
We may transfer your personal information to countries or territories whose laws have **not ****been deemed to provide such an adequate level of protection (e.g., the U.S.).
However, in these cases:
we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
Cookie Policy
What does this Cookie Policy cover?
This Cookie Policy explains how NdotLight Co., Ltd. (“NdotLight,” “Surfee,” “we”, “us” or “our”) uses cookies and other similar technologies on our websites that link to this Cookie Policy (the “Site”), as well as in our emails. It also outlines your choices around managing these cookies and similar technologies.
Please refer to our Privacy Policy for more information on our privacy practices.
Managing your preferences
Before we dive into the details – if you are just looking to manage your preferences on our Site relating to cookies and similar technologies (including opting-out), you can do so at any time through our [Consent Preference Centre]
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your device and you may need to log in every time you visit our Site.
If you want to find out more about cookies and similar technologies on our Site and emails, please keep reading.
What types of technologies does NdotLight use?
We may use any or all of the following “technologies” on our Site and in our emails:
Cookies: a cookie is a very small text file that may be placed on your browser or in the storage on your device. There are two types: “session cookies” and “persistent cookies”:
Session cookies are cookies that disappear from your device or browser when you close your browser.
Persistent cookies stay on your device even after you close your browser.
Please note that both NdotLight and third-party service providers may set cookies via our Site – these ‘third party cookies’ are set by domains other than those we control and may recognise your device across different websites.
Other similar technologies:
We may also use other tracking technologies for similar purposes as described in this Cookie Policy. Such technologies include:
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Session-replay technologies, such as those provided by Sentry that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Sentry at https://sentry.io/privacy/.
So, when we refer to cookies and “similar technologies” in this Cookie Policy, such reference includes reference to the pixel tags discussed above, HTML5 local storage / local shared objects and other equivalent tracking technologies.
Why do we use cookies and similar technologies?
The purposes for which we use technologies may fall into one of the following categories:
[Strictly necessary technologies: these technologies are essential in order to enable our Site to provide the function you have requested, such as by helping to ensure that the content of a page loads quickly and effectively.]
[Functionality technologies: these technologies allow us to provide enhanced personalisation and functionality, such as tailoring content to you, remembering your choices and preferences on the Site (e.g. language, text size, etc.) or remembering search parameters.]
[Analytics technologies: these technologies collect information on how users interact with our Site and enable us to improve how it operates and our business more widely.
[Advertising technologies: these technologies are deployed on the Site and collect information about your browsing habits in order to provide advertising which is more relevant to you and your interests – for example, they remember the websites you have visited and share that information with other parties such as advertising technology service providers.]
[Social media technologies: these technologies are used when you share information using a social media sharing or “like” button on our Site or social media platform. This information may be linked to advertising activities.]
A full list of the technologies we use can be found in the section titled: Details of Cookies and Similar Technologies.
How can you manage your consent?
You can control or limit how cookies and similar technologies are used by taking the following steps:
Managing your preferences on our Site (including by opting-out) at any time by using our [Consent Preference Centre] here: https://surfee.io/cookies
Pixel tags in emails can typically be blocked by default by configuring your preferences in your email client to block external images or setting it to show “plain text only” emails.
For more information about cookies, including about the cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Also, to learn more about targeting and advertising cookies and your choices more widely, you can go to the Network Advertising Initiative, the Digital Advertising Alliance’s Consumer Choice, or if you are in Europe, Your Online Choices.
Finally, if you do not accept certain non-essential cookies and similar technologies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your device and you may need to log in every time you visit our Site.
Details of Cookies and Similar Technologies
Please click here to view details of the specific cookies and other similar technologies that we use. The details shown at this link (including the cookies and other similar technologies shown there) may change over time.
Changes to this Cookie Policy
Information about the cookies and similar technologies we use may be updated from time to time, so please check this Cookie Policy on a regular basis for any changes.
Questions
If you have any questions about this Cookie Policy, please contact us by email at support@surfee.io
LAST UPDATE: May 26, 2025
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the ‘Compliance and protection’ purposes outlined above.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information that we have collected about you, we will either delete or anonymize it 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other information
No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.
No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.
Your additional rights
General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision.
We may transfer your personal information to countries or territories whose laws have **not ****been deemed to provide such an adequate level of protection (e.g., the U.S.).
However, in these cases:
we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
Cookie Policy
What does this Cookie Policy cover?
This Cookie Policy explains how NdotLight Co., Ltd. (“NdotLight,” “Surfee,” “we”, “us” or “our”) uses cookies and other similar technologies on our websites that link to this Cookie Policy (the “Site”), as well as in our emails. It also outlines your choices around managing these cookies and similar technologies.
Please refer to our Privacy Policy for more information on our privacy practices.
Managing your preferences
Before we dive into the details – if you are just looking to manage your preferences on our Site relating to cookies and similar technologies (including opting-out), you can do so at any time through our [Consent Preference Centre]
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your device and you may need to log in every time you visit our Site.
If you want to find out more about cookies and similar technologies on our Site and emails, please keep reading.
What types of technologies does NdotLight use?
We may use any or all of the following “technologies” on our Site and in our emails:
Cookies: a cookie is a very small text file that may be placed on your browser or in the storage on your device. There are two types: “session cookies” and “persistent cookies”:
Session cookies are cookies that disappear from your device or browser when you close your browser.
Persistent cookies stay on your device even after you close your browser.
Please note that both NdotLight and third-party service providers may set cookies via our Site – these ‘third party cookies’ are set by domains other than those we control and may recognise your device across different websites.
Other similar technologies:
We may also use other tracking technologies for similar purposes as described in this Cookie Policy. Such technologies include:
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Session-replay technologies, such as those provided by Sentry that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Sentry at https://sentry.io/privacy/.
So, when we refer to cookies and “similar technologies” in this Cookie Policy, such reference includes reference to the pixel tags discussed above, HTML5 local storage / local shared objects and other equivalent tracking technologies.
Why do we use cookies and similar technologies?
The purposes for which we use technologies may fall into one of the following categories:
[Strictly necessary technologies: these technologies are essential in order to enable our Site to provide the function you have requested, such as by helping to ensure that the content of a page loads quickly and effectively.]
[Functionality technologies: these technologies allow us to provide enhanced personalisation and functionality, such as tailoring content to you, remembering your choices and preferences on the Site (e.g. language, text size, etc.) or remembering search parameters.]
[Analytics technologies: these technologies collect information on how users interact with our Site and enable us to improve how it operates and our business more widely.
[Advertising technologies: these technologies are deployed on the Site and collect information about your browsing habits in order to provide advertising which is more relevant to you and your interests – for example, they remember the websites you have visited and share that information with other parties such as advertising technology service providers.]
[Social media technologies: these technologies are used when you share information using a social media sharing or “like” button on our Site or social media platform. This information may be linked to advertising activities.]
A full list of the technologies we use can be found in the section titled: Details of Cookies and Similar Technologies.
How can you manage your consent?
You can control or limit how cookies and similar technologies are used by taking the following steps:
Managing your preferences on our Site (including by opting-out) at any time by using our [Consent Preference Centre] here: https://surfee.io/cookies
Pixel tags in emails can typically be blocked by default by configuring your preferences in your email client to block external images or setting it to show “plain text only” emails.
For more information about cookies, including about the cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Also, to learn more about targeting and advertising cookies and your choices more widely, you can go to the Network Advertising Initiative, the Digital Advertising Alliance’s Consumer Choice, or if you are in Europe, Your Online Choices.
Finally, if you do not accept certain non-essential cookies and similar technologies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your device and you may need to log in every time you visit our Site.
Details of Cookies and Similar Technologies
Please click here to view details of the specific cookies and other similar technologies that we use. The details shown at this link (including the cookies and other similar technologies shown there) may change over time.
Changes to this Cookie Policy
Information about the cookies and similar technologies we use may be updated from time to time, so please check this Cookie Policy on a regular basis for any changes.
Questions
If you have any questions about this Cookie Policy, please contact us by email at support@surfee.io
LAST UPDATE: May 26, 2025
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the ‘Compliance and protection’ purposes outlined above.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information that we have collected about you, we will either delete or anonymize it 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other information
No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.
No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.
Your additional rights
General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision.
We may transfer your personal information to countries or territories whose laws have **not ****been deemed to provide such an adequate level of protection (e.g., the U.S.).
However, in these cases:
we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
Cookie Policy
What does this Cookie Policy cover?
This Cookie Policy explains how NdotLight Co., Ltd. (“NdotLight,” “Surfee,” “we”, “us” or “our”) uses cookies and other similar technologies on our websites that link to this Cookie Policy (the “Site”), as well as in our emails. It also outlines your choices around managing these cookies and similar technologies.
Please refer to our Privacy Policy for more information on our privacy practices.
Managing your preferences
Before we dive into the details – if you are just looking to manage your preferences on our Site relating to cookies and similar technologies (including opting-out), you can do so at any time through our [Consent Preference Centre]
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your device and you may need to log in every time you visit our Site.
If you want to find out more about cookies and similar technologies on our Site and emails, please keep reading.
What types of technologies does NdotLight use?
We may use any or all of the following “technologies” on our Site and in our emails:
Cookies: a cookie is a very small text file that may be placed on your browser or in the storage on your device. There are two types: “session cookies” and “persistent cookies”:
Session cookies are cookies that disappear from your device or browser when you close your browser.
Persistent cookies stay on your device even after you close your browser.
Please note that both NdotLight and third-party service providers may set cookies via our Site – these ‘third party cookies’ are set by domains other than those we control and may recognise your device across different websites.
Other similar technologies:
We may also use other tracking technologies for similar purposes as described in this Cookie Policy. Such technologies include:
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Session-replay technologies, such as those provided by Sentry that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Sentry at https://sentry.io/privacy/.
So, when we refer to cookies and “similar technologies” in this Cookie Policy, such reference includes reference to the pixel tags discussed above, HTML5 local storage / local shared objects and other equivalent tracking technologies.
Why do we use cookies and similar technologies?
The purposes for which we use technologies may fall into one of the following categories:
[Strictly necessary technologies: these technologies are essential in order to enable our Site to provide the function you have requested, such as by helping to ensure that the content of a page loads quickly and effectively.]
[Functionality technologies: these technologies allow us to provide enhanced personalisation and functionality, such as tailoring content to you, remembering your choices and preferences on the Site (e.g. language, text size, etc.) or remembering search parameters.]
[Analytics technologies: these technologies collect information on how users interact with our Site and enable us to improve how it operates and our business more widely.
[Advertising technologies: these technologies are deployed on the Site and collect information about your browsing habits in order to provide advertising which is more relevant to you and your interests – for example, they remember the websites you have visited and share that information with other parties such as advertising technology service providers.]
[Social media technologies: these technologies are used when you share information using a social media sharing or “like” button on our Site or social media platform. This information may be linked to advertising activities.]
A full list of the technologies we use can be found in the section titled: Details of Cookies and Similar Technologies.
How can you manage your consent?
You can control or limit how cookies and similar technologies are used by taking the following steps:
Managing your preferences on our Site (including by opting-out) at any time by using our [Consent Preference Centre] here: https://surfee.io/cookies
Pixel tags in emails can typically be blocked by default by configuring your preferences in your email client to block external images or setting it to show “plain text only” emails.
For more information about cookies, including about the cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Also, to learn more about targeting and advertising cookies and your choices more widely, you can go to the Network Advertising Initiative, the Digital Advertising Alliance’s Consumer Choice, or if you are in Europe, Your Online Choices.
Finally, if you do not accept certain non-essential cookies and similar technologies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your device and you may need to log in every time you visit our Site.
Details of Cookies and Similar Technologies
Please click here to view details of the specific cookies and other similar technologies that we use. The details shown at this link (including the cookies and other similar technologies shown there) may change over time.
Changes to this Cookie Policy
Information about the cookies and similar technologies we use may be updated from time to time, so please check this Cookie Policy on a regular basis for any changes.
Questions
If you have any questions about this Cookie Policy, please contact us by email at support@surfee.io
LAST UPDATE: May 26, 2025