Seller: Superspeed.ai Pty Ltd
IP Owner & Licensor: Strategic Global Holdings Pty Ltd (ACN 693 256 503)
Effective Date: 1 January 2025
Version: 4.95 Ultra-Final
Document Owner: CEO, Superspeed.ai Pty Ltd
Review Cycle: Annual or upon regulatory change
1. Definitions
Defines key terms under the PRC Personal Information Protection Law (PIPL), including: Personal Information, Processing, Entrusted Processor, Sensitive Personal Information, Cross-Border Transfer, Separate Consent, and Automated Decision-Making.
2. Purpose & Scope
This Addendum applies to individuals located in the PRC and supplements the Global Privacy Policy. Where inconsistencies exist, this Addendum prevails for PRC users.
3. Lawful Bases for Processing
Under PIPL, processing must be based on a lawful ground. We process data under:
- Contract necessity (order fulfilment, digital downloads)
- Separate, informed consent (marketing, cookies)
- Legal obligations (tax, compliance)
- Public interest (rare)
- Security and fraud prevention (legitimate need)
4. Sensitive Personal Information
We do not collect Sensitive Personal Information as defined under PIPL, including biometric, health, financial, location-tracking, or minors’ data without verified guardian consent.
5. Cross-Border Transfers
Where Personal Information is transferred outside China (e.g., Australia), we obtain separate consent and ensure adequate protection measures, which may include:
- Standard contracts filed with the CAC
- Security assessments where required
- Technical measures including encryption and access controls
6. Data Subject Rights
Under PIPL, individuals have rights to:
- Access their Personal Information
- Correct inaccuracies
- Request deletion under lawful grounds
- Withdraw consent at any time
- Request explanation of automated processing
- Object to significant automated decision-making
7. Automated Decision-Making
We do not use automated decision-making that materially affects users. Profiling for personalisation is optional and may be disabled. Human oversight is always available.
8. Children’s Data
We do not knowingly process data of children under 14 without verified parental or guardian consent.
9. Data Retention & Minimisation
Personal Information is retained only for the shortest period necessary to meet processing purposes or legal requirements.
10. Withdrawal of Consent
Consent may be withdrawn at any time by contacting support@superspeed.ai. Withdrawal does not affect prior lawful processing.
11. Cross-Document Integration
This Addendum must be read with the Global Privacy Policy, Cookie Notice, Cookie Preferences Policy, and Automated Decision-Making & Profiling Disclosure.