Privacy Policy

Who we are

Our website address is:

This is our current policy, if you have questions please contact us.

At Supplino, we care about your privacy. For this reason, we collect and use personal data only as it might be needed for us to deliver to you our services, products, websites and mobile applications (collectively, our “Services”). This privacy policy describes how our Company and Services comply with relevant data protection regulation, including GDPR. We will not repeat any GDPR legislation text or explanations here but the can be accesses here. We protect your data according to all relevant regulations to the best of our capabilities.

This policy was last updated March 4th, 2019.

We are Supplino 

Supplino’s registered office is at 2093 Philapdephia Pike #2090
Claymont, DE 19703, United States. The company is registered in the USA.

The appointed contact for privacy and IT security matters is Eugenio Grapa, CTO, and can be contacted at

We operate multiple websites, including, and

What information do we collect?

Supplino’s business is developing and delivering supply chain services and trainings to entrepreneurs and small businesses. We collect information so that we can provide the best possible experience when you utilise our Services. Much of what you likely consider personal data is collected directly from you when you:

  • write or email us, we collect contact information;
  • create an account or purchase any of our Services (ex: billing information, purchase history and other transactional information, including name, address, credit card number);
  • request assistance from our customer support team (ex: phone number);
  • participate in a learning module, We also collect learning progress records.
  • complete contact forms or request newsletters or other information from us (ex: email); or
  • participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.

Also, we may collect additional information when delivering our Services to you to ensure necessary and optimal performance. 

These methods of collection may not be as obvious, so we do want to highlight and explain a bit more about what these might be, how they vary from time to time, and how they work:

Account related information is collected in association with the use of our Services, such as account number, purchases, when products renew or expire, information requests, and customer service requests and notes or details explaining what was asked for and how we responded.

Cookies and similar technologies on our websites and our mobile applications allow us to track browsing behaviour, links clicked, items purchased, device type, and to collect various data, including analytics, about how people use and interact with our Services. This allows us to provide users with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyse and improve the performance of our Services. 

We may also collect user location (IP address) so that we can personalise our Services. For additional information, and to learn how to manage the technologies we utilise, please visit our Cookie Policy.

Data about Usage of Services is automatically collected when users use and interact with our Services, including metadata, log files, cookie/device IDs, page load time, server response time, and approximate location information to measure website performance and improve our systems. Specifically, interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data is collected.

Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyse the accuracy of our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

How we utilise information

We believe in both minimising the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes. These uses include:

  • data to deliver on the purchases that you have made with us, or purchases that were made on your behalf.
  • data to send you valuable tips including information about relevant products, but only if you have given us consent for that.
  • data to reduce fraud and other abuse of our systems.

Data retention 

We keep personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

  • mandated by law, contract or similar obligations applicable to our business operations;
  • for preserving, resolving, defending or enforcing our legal/contractual rights; or
  • needed to maintain adequate and accurate business and financial records.

Sharing with trusted third parties 

We may share your personal data with affiliated companies, with third parties with which we have partnered to integrate their services into our own Services, and with trusted third party service providers as requested or as needed for them to perform services on our behalf, such as:

  • Processing credit card payments,
  • Serving advertisements,
  • Conducting contests or surveys,
  • Performing analysis of our Services and customers demographics,
  • Communicating with you, such as by way email or survey delivery,
  • Customer relationship management,
  • Supply chain request management.

We only share your personal data as necessary for third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).

We may also share your information with third parties for the purpose of facilitating/allowing a merger, acquisition or sale of all or substantially all of our assets, in which case the acquiring company may continue to utilise your data in the manner for which it was provided and intended.

We will not hand over your data to other parties other than what is legally required or required for the delivery of our products and services.

Communicating with you 

We may contact you directly or through a third party service provider regarding our Services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:

  • Email 
  • Text (SMS) messages
  • Telephone calls
  • Browser, mobile or system notifications
  • Automated phone calls or text messages.

You may also update your subscription preferences with respect to receiving communications from us and/or our partners by signing into your account and visiting “Account Settings” page.

If we collect information from you in connection with a co-branded, partner offer, it will be clear at the point of collection who is collecting the information and whose privacy policy applies. In addition, it will describe any choice options you have in regards to the use and/or sharing of your personal data with a co-branded partner, as well as how to exercise those options.

Transfer of personal data abroad

If you utilise our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders. Also, when you call us or initiate a chat, we may provide you with support from our locations outside your country of origin. In these cases, your personal data is handled according to this Privacy Policy.

The following table lists the personal data that we control, with their locations and processors or the 3rd parties that we share information with. The location column contains a link to the respective privacy policy. We deem all non EEA (European Economic Area) parties to provide adequate protection.

hosting Marketing: Website hosting User accounts, cookie content.
Google Analytics Web analytics Web access metadata US
Google Docs Email and file hosting, forms Personal data US
Laptops Document processing, communications Personal data EEA
Phones Communications Personal data EEA Delivery of E-learning Contact details, course progress US Delivery of E-learning Contact details, course progress US Service delivery: Payments Payment and contact info EEA
Silicon Valley Bank Service delivery: Payments Payment and contact info US
Cloud Security Alliance, US. Exam token provisioning Contact information US
Personal assistant Administrative support Personal data EEA Administrative support Personal data EEA Website backup / document support User accounts, cookie content US Service delivery: team communications Accounts of learners US Voice and chat communications Personal address details US Voice and chat communications Personal address details US
calendar tool Appointment scheduling Personal address details US
Google reCAPTCHA Troll control Browser details US
Zapier Marketing and delivery automation Personal data US email managementPersonal data EEA
airtable.comdata managementPersonal data US

Compliance with legal, regulatory and law enforcement requests 

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process. 

Website and mobile analytics 

We use multiple web and mobile analytics tools provided by service partners such as Google Analytics, AppleStore to collect information about how you interact with our website or mobile applications, including what pages you visit, what site you visited prior to visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our Services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Each cookie cannot be used by anyone other than the service provider (ex: Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies we use by managing your settings through our Cookie Policy or the “cookie banners” that may be presented when you first visit our webpages, or by utilizing settings in your browser or third-party tools.

Third-party websites or mobile apps

Our website and our mobile applications may contain links to third-party websites or mobile applications. We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit or mobile application that you use.

Acccess, update or delete your data

To easily access, view, update, delete or port your personal data (where available), or to update your subscription preferences, please sign into your Account and visit “Account Settings.” 

If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

If you are unable for any reason to access your Account Settings, you may also contact us by one of the methods described in the “Contact Us” section below.

How we secure, store your data

We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilisation of encryption where appropriate.

‘Do Not Track’ notifications.

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit

Age restrictions and Medical Data

Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.

We do not collect any medical information.

Changes in our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. 

If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

Data Protection Authority

If you are a resident of the European Economic Area (EEA) and believe we maintain your personal data subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local supervisory authority.

Contact us

If you have any privacy-related questions, concerns or complaints about our Privacy Policy, our practices or our Services, you may contact us at In the alternative, you may contact us by the following means:

  • By Mail: Attn: Data Protection Officer, Supplino, Inc., 2093 Philapdephia Pike #2090, Claymont, DE 19703, United States

We will respond to all requests, inquiries or concerns within thirty (30) days.