PRIVACY POLICY

1. Roles: SGEN vs. Our Customers (Important)

SGEN is a platform that helps customers build, host, and manage websites and related functionality (e.g., forms, ecommerce, analytics, integrations).

**Account/Platform Data:** For information we collect about you as an SGEN account holder (e.g., your login, billing, and platform usage), SGEN generally acts as a data controller.

**Customer Website Data:** For information collected through websites built on SGEN (e.g., form submissions, customer orders, visitor analytics configured by the customer), the SGEN customer is typically the data controller, and SGEN acts as a service provider/processor processing that data on the customer's behalf.

If you are an End User of a customer's website, please review that website's privacy policy for information about the customer's practices and your choices.

2. Information We Collect

We collect information in three main ways: (A) information you provide, (B) information collected automatically, and (C) information from third parties.

A) Information You Provide

**Account Registration.** Name, email address, password (stored in hashed form), and optional profile details such as company name and profile photo.

**Billing and Subscription.** Billing contact details and subscription status. Payment information is processed by third-party payment processors (e.g., Stripe). We do not store full payment card numbers on our systems.

**Content and Configuration.** Content you upload or create (websites, pages, media, products), plus settings/configuration you apply within the platform.

**Communications.** Information you send via support requests, surveys, feedback, or other communications.

**Phone Number.** We may collect your phone number for account verification and to send one-time passwords (OTPs) via SMS. We do not use your phone number for marketing purposes. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. SMS opt-in data and consent will not be shared with any third party.

B) Information Collected Automatically

**Device and Network Data.** Browser type, operating system, device identifiers, IP address, approximate location (derived from IP), and similar technical data.

**Log and Activity Data.** Access times, pages viewed, actions taken in the platform, referring URLs, error logs, and performance data.

**Usage Analytics.** Interaction patterns, feature usage, time spent, navigation paths, and diagnostic events.

**Cookies and Similar Technologies.** We use cookies, pixels, local storage, and similar technologies for authentication, security, preferences, analytics, and (where applicable) marketing. See our Cookie Policy: /legal/cookies.

C) Information from Third Parties

**OAuth Providers.** If you sign in using Google, GitHub, or other OAuth providers, we receive basic profile information (such as name, email address, and profile photo) as authorized by you.

**Analytics Providers.** We may receive aggregated or event-level analytics signals from analytics providers you or we use.

**Payment Processors.** We receive payment confirmations, billing status, and subscription metadata from our payment processors.

3. How We Use Information

We use information to:

• provide, operate, maintain, and improve the Services;
• create and manage accounts, authentication, and security;
• process subscriptions and send invoices, receipts, and service communications;
• provide support, respond to requests, and communicate with you;
• monitor and analyze usage, performance, and trends;
• detect, prevent, and investigate fraud, abuse, security incidents, and illegal activity;
• enforce our Terms of Service and Acceptable Use Policy; and 
• comply with legal obligations.

Aggregated / De-Identified Data

We may generate and use aggregated and/or de-identified data derived from use of the Services (e.g., platform performance metrics, feature adoption, reliability statistics). This data does not identify you or your End Users and may be used for product improvement and business analytics.

4. Legal Bases for Processing (EEA/UK)

If you are located in the EEA or UK, we process personal data under one or more of these legal bases:

**Contract.** To provide the Services you request.

**Legitimate Interests.** To operate, secure, and improve the Services, prevent fraud/abuse, and communicate about the Services (where permitted).

**Legal Obligations.** To comply with applicable law (e.g., tax, lawful requests).

**Consent.** Where required (e.g., certain cookies, marketing communications in some jurisdictions). You can withdraw consent where applicable.

5. Google API Services User Data (Limited Use)

SGEN's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

When you connect your Google account to SGEN, we may request access to certain Google services to provide specific features. Examples include:

Google Account (Basic Profile)

• Scope: email, profile, openid
• Purpose: account creation and authentication; profile personalization.

Google Search Console

• Scope: webmasters.readonly
• Purpose: display search performance data in your dashboard (read-only).

Google Analytics

• Scope: analytics.readonly
• Purpose: display analytics data in your dashboard (read-only).

Google Business Profile

• Scope: business.manage
• Purpose: allow you to manage your Business Profile from within SGEN at your direction.

Limited Use Compliance

• We use Google data only for the purposes described and to display to you in the app.
• We do not sell Google user data.
• We do not use Google user data for advertising.
• We do not transfer Google user data to third parties except as necessary to provide the Services, with your consent, or as required by law.
• Human access to Google user data is limited to support needs with your affirmative consent or where required by law.

6. How We Share Information

**We do not sell your personal information.**

We share information only in the following circumstances:

Service Providers

We share information with vendors who help us operate the Services (e.g., cloud hosting, content delivery, monitoring, email delivery, customer support tooling, payment processing). They are permitted to process information only to provide services to us and must protect it under contractual obligations.

Integrations You Enable

If you connect third-party services (e.g., analytics, CRMs, email providers), those third parties may receive data as part of the integration. Your use of third-party services is governed by their terms and privacy policies.

Legal and Safety

We may disclose information to comply with law, subpoenas, court orders, or lawful government requests, or to protect the rights, safety, and security of SGEN, our users, or others. Where permitted, we may notify you before disclosing information.

Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction.

Aggregated / De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you.

7. Data Retention

We retain information for as long as necessary to provide the Services and for legitimate business or legal purposes (such as security, dispute resolution, and compliance).

Typical retention periods (which may vary depending on product configuration, legal requirements, and operational needs):

**Account Data:** retained while your account is active; if you delete your account, we will delete or de-identify personal account data within a commercially reasonable time, unless we must retain it for legal or legitimate purposes.

**Customer Website Content/Data:** retained while the customer account is active; deletion timing may depend on customer actions and platform configuration.

**Billing/Tax Records:** retained as required by law and standard accounting practices.

**Security Logs:** retained for a limited period appropriate for security and debugging.

**Aggregated/De-identified Analytics:** may be retained longer.

8. Your Rights and Choices

All Users

**Marketing emails:** you can unsubscribe using the link in our emails (transactional/service emails may still be sent).

**Cookies:** manage preferences through our cookie banner (where available) and/or browser settings.

**Account controls:** you may access, update, or delete certain information through your account settings (where available).

EEA/UK (GDPR)

You may have rights to access, correct, delete, restrict processing, object, and data portability, and to withdraw consent where applicable.

California (CCPA/CPRA)

California residents may have rights to know, access, delete, correct, and opt-out of certain "sharing"/targeted advertising where applicable. SGEN does not sell personal information.

Exercising Rights

To exercise privacy rights, contact privacy@sgen.com. We may need to verify your identity.

9. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect information. However, no system is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for using strong passwords and available security features.

10. International Data Transfers

SGEN is based in the United States, and information may be processed in the United States and other countries where we or our service providers operate.

Where required, we use appropriate safeguards for international transfers (such as Standard Contractual Clauses) or other lawful mechanisms.

11. Children's Privacy

The Services are not directed to children under 13 (or under 16 in certain jurisdictions). We do not knowingly collect personal information from children. If you believe a child provided personal information, contact privacy@sgen.com and we will take appropriate steps.

12. Cookies and Tracking Technologies

We use cookies and similar technologies for authentication, security, preferences, analytics, and (where applicable) marketing. See our Cookie Policy: /legal/cookies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will update the "Last Updated" date above. If changes are material, we may provide additional notice (e.g., email or in-product notice) as required by law.

14. Contact

**Legal:** legal@sgen.com

**Company:** NEGS117 LLC d/b/a SGEN

**Address:** 360 E Desert Inn Rd #1501 Las Vegas 89109