Privacy Policy

Merchant Protocol LLC, doing business as Sulla Desktop ("we," "our," or "us"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our desktop application and visit our website. Please read this privacy policy carefully.

1. Information We Collect

1.1 Information You Provide Directly

We only collect information that you voluntarily provide to us. This may include:

• Newsletter Subscription: When you opt-in to our newsletter, we collect your name and email address
• Support Requests: Information you provide when contacting us for support
• Feedback and Surveys: Any information you provide in response to surveys or feedback requests

1.2 Automatically Collected Information

When you visit our website, we automatically collect certain information through analytics and tracking technologies:

• Device Information: Browser type, operating system, device type, screen resolution
• Usage Data: Pages viewed, time spent on pages, click patterns, scroll depth
• Log Information: IP address, access times, referring URLs
• Location Data: Country, region, and city (derived from IP address)
• Analytics Data: User behavior, conversion events, and interaction patterns
• Cookies and similar tracking technologies (see Section 5)

1.3 Analytics Services

We use the following analytics services to understand how users interact with our website and products:

• Google Analytics: For website traffic analysis and user behavior tracking
• Google Tag Manager: To manage and deploy tracking codes
• PostHog: For product analytics, feature usage, and user journey tracking in both our website and desktop application

These services collect data using cookies, pixel tags, and similar technologies. The information collected includes but is not limited to page views, session duration, bounce rates, and conversion events.

1.4 Desktop Application

Sulla Desktop uses PostHog for anonymous product analytics to help us improve the application. We collect:

• Feature usage statistics (which features are used most)
• Performance metrics (load times, response times)
• Error reports and crash data
• Anonymous usage patterns

Important: We do NOT collect or access your personal files, AI conversations, or any sensitive data. All analytics data is anonymized and used solely to improve the product. You can opt-out of analytics collection in the application settings.

2. How We Use Your Information

We use the information we collect to:

• Send newsletters and updates (only if you've opted in)
• Respond to your support requests and inquiries
• Improve our products and services based on usage patterns
• Display targeted advertisements through remarketing campaigns
• Analyze website traffic and optimize user experience
• Track conversion events and marketing campaign effectiveness
• Personalize your experience on our website
• Send important notices about changes to our terms or policies
• Comply with legal obligations
• Protect against fraudulent or illegal activity

3. How We Share Your Information

We do not sell, trade, or rent your personal information. We may share your information only in the following circumstances:

3.1 Service Providers

We may share your information with third-party vendors who provide services on our behalf, including:

• Analytics Providers: Google Analytics, PostHog, Google Tag Manager
• Advertising Partners: Facebook/Meta, Google Ads, YouTube, LinkedIn
• Email Service Providers: For newsletter distribution and transactional emails
• Customer Support Platforms: To manage support tickets and inquiries
• Payment Processors: For marketplace transactions and premium features
• Content Delivery Networks: To serve website content efficiently

These service providers are contractually obligated to protect your information and use it only for the purposes we specify. They may process your data in accordance with their own privacy policies, which we encourage you to review.

3.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid legal requests, including:

• Court orders or subpoenas
• Government or regulatory requests
• To protect our rights, property, or safety
• To prevent fraud or illegal activities

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity.

4. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit
• Secure storage systems
• Limited access to personal information
• Regular security assessments

However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

5. Cookies and Tracking Technologies

5.1 Types of Cookies We Use

• Essential Cookies: Required for the website to function properly
• Analytics Cookies: Help us understand how visitors interact with our website
• Marketing Cookies: Used to track visitors across websites for remarketing purposes
• Preference Cookies: Remember your settings and preferences

5.2 Remarketing and Advertising

We use remarketing pixels and tags to display targeted advertisements to you after you visit our website. These technologies include:

• Facebook Pixel: To show you relevant ads on Facebook and Instagram
• Google Ads Remarketing: To display ads across Google's advertising network
• YouTube Tags: To show video advertisements on YouTube
• LinkedIn Insight Tag: For B2B remarketing campaigns

These pixels collect information about your browsing behavior, including:

• Pages you visit on our website
• Products or features you view
• Actions you take (downloads, sign-ups, etc.)
• Your IP address and device information

This allows us to show you relevant advertisements about Sulla Desktop on other platforms. You can opt-out of remarketing by:

• Using the Digital Advertising Alliance opt-out page
• Adjusting your ad preferences on Facebook
• Using Google Ads Settings
• Installing an ad blocker or using browser privacy settings

5.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling cookies may affect the functionality of our website and prevent you from using certain features.

6. Your Rights and Choices

6.1 Opt-Out

You can opt-out of receiving marketing communications from us at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Contacting us at [email protected]

6.2 Access and Correction

You have the right to request access to the personal information we hold about you and to request corrections if it is inaccurate.

6.3 Deletion

You may request that we delete your personal information, subject to certain legal exceptions.

6.4 Data Portability

You have the right to request a copy of your personal information in a structured, commonly used format.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy.

8. Children's Privacy

Our services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information.

9. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

• The right to know what personal information we collect, use, and disclose
• The right to delete your personal information
• The right to opt-out of the sale of personal information (we do not sell personal information)
• The right to non-discrimination for exercising your privacy rights

10. European Privacy Rights

If you are located in the European Economic Area (EEA) or United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR), including:

• The right to be informed about how we use your data
• The right to access your personal data
• The right to rectification of inaccurate data
• The right to erasure ("right to be forgotten")
• The right to restrict processing
• The right to data portability
• The right to object to processing
• Rights related to automated decision-making

11. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. When we no longer need your information, we will securely delete or anonymize it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

14. Legal Basis for Processing (EEA/UK)

If you are located in the EEA or UK, our legal basis for collecting and using your personal information depends on the specific context in which we collect it:

• Consent: When you opt-in to our newsletter
• Contract: When necessary to provide services you've requested
• Legal Obligation: When we must comply with applicable laws
• Legitimate Interests: When necessary for our legitimate business interests, except where overridden by your rights and interests

15. Do Not Track

Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. We currently do not respond to browser "Do Not Track" signals.

16. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these third-party sites. We encourage you to read their privacy policies before providing any personal information.