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Privacy Policy

Last Updated: October 29, 2025

Welcome to Surfluent (“Company,” “we,” “us,” or “our”). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our web application, browser extension, and related services (collectively, the “Service”).

For the purposes of the General Data Protection Regulation (GDPR), Golden River Technologies, LLC dba Surfluent is the “Data Controller” of the personal information we collect from you.

Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy. This Privacy Policy is incorporated by reference into our Terms and Conditions.

1. Information We Collect

We collect information in a few different ways to provide and improve our Service.

1.1. Information You Provide to Us

Account Information: When you sign up for the Service, we collect your First Name, Last Name, and Email Address. We also store a secure, one-way hash of your Password (we never store the password itself).

User Content: When you highlight or save a word or phrase to your study list, we store that content and link it to your account so you can access it later.

1.2. Information We Collect Automatically

Web Server Logs: When you interact with our Service, our servers automatically record standard information that your browser sends. This includes your IP Address, browser type and version (e.g., Chrome 125), and general device information (e.g., Windows, macOS). We use this for security and debugging.

Usage Data: To power your personal dashboard and manage your subscription, we collect data about your interactions with the Service. This includes Translation Events (the date and number of words translated) and Highlight Events (the date and the specific phrase you highlighted). This data is always linked to your user account.

1.3. Payment Information

We use Stripe, a third-party payment processor, to handle all subscription payments. We do not collect, receive, or store any of your sensitive payment information, such as your full credit card number. This information is provided directly to Stripe, whose use of your personal information is governed by their privacy policy.

1.4. Information We Intentionally Do Not Collect

Privacy is a core feature of our Service. The browser extension is designed to not send the URL or any other identifying information about the specific websites you visit to our servers. Our servers receive the text you select for translation but have no knowledge of where that text came from. Additionally, we do not automatically save the full translated page.

2. How We Use Your Information

We use the information we collect for the purposes listed below.

  • To Provide and Maintain the Service: To create your account, provide you with your dashboard and study lists, and manage your subscription.
  • To Improve the Service: To understand how our users interact with the Service, fix bugs, and develop new features.
  • To Communicate With You: To send you important information about your account (e.g., billing receipts, password resets) and, with your consent, to send you marketing emails about product updates and special offers. You can opt out of marketing emails at any time.
  • For Security and Fraud Prevention: To monitor for malicious activity, protect our servers, and enforce our Terms and Conditions.

2.1. Legal Basis for Processing (for EEA Users)

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. Our legal bases are:

  • Performance of a Contract: We need to process your personal data to provide the Service you signed up for, including managing your account and subscription.
  • Legitimate Interests: We process your information for our legitimate interests, such as for security and service improvement, provided these interests are not overridden by your data protection interests.
  • Consent: We will process your information for sending marketing communications only with your explicit consent.

3. How We Share Your Information

We do not sell your personal information. We only share it with trusted third parties who help us operate our business, as described below:

Service Providers: We share information with third-party vendors who perform services on our behalf. These include:

  • Render: Our hosting provider.
  • Supabase: Our database provider.
  • Stripe: Our payment processing provider.
  • Cloudflare: Our web performance and security provider.
  • Postmark: Our email provider.
  • Google Gemini: Our AI translation provider.

Analytics Providers: We use Google Analytics to help analyze how our users use the Service. Google Analytics uses cookies to collect and store information such as pages visited, time spent on pages, and websites visited just before and after ours. You can learn more about Google's practices by visiting their Privacy & Terms page and can opt out of being tracked by Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

Legal Requirements: We may disclose your information if required to do so by law or in response to a valid request by public authorities (e.g., a court or government agency).

Business Transfers: If we are involved in a merger, acquisition, or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

4. Data Retention

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Typically, this means we keep your account information as long as your account is active.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

What Are Cookies? Cookies are small files placed on your computer or device by a website. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

How We Use Cookies: We use cookies for the following purposes:

  • Strictly Necessary Cookies: These are essential for the operation of our Service, such as keeping you logged in to your account.
  • Performance and Analytics Cookies: These help us understand how you use our Service so we can improve it.

Your Choices: Most web browsers are set to accept cookies by default. You can usually modify your browser setting to decline cookies if you prefer. However, if you disable cookies, some features of the Service may not function properly.

6. Your Data Rights and Choices

We provide you with choices regarding the information you provide to us.

Access, Update, or Delete Your Information: You can access and update most of your account information through your account settings page. You may also request to delete your account and associated personal information by contacting us.

Opt-Out of Marketing Communications: You may opt out of receiving marketing emails from us by following the "unsubscribe" link provided in those emails or emailing us at privacy@surfluent.com.

6.1. Rights for European Economic Area (EEA) Residents (GDPR)

If you are a resident of the EEA, you have certain data protection rights, including the right to access, rectify, object to, restrict, or erase your data, the right to data portability, and the right to lodge a complaint with a data protection authority.

6.2. Rights for California Residents (CCPA)

If you are a California resident, you have the right to know what personal information we collect, the right to access it, and the right to have it deleted. We do not "sell" your personal information.

6.3. Do Not Track Disclosure

Some web browsers may transmit "Do Not Track" (DNT) signals. There is no industry standard for how to respond to these signals. Therefore, we do not currently take action in response to DNT signals. To exercise any of these rights, please contact us privacy@surfluent.com. For your protection, we may need to verify your identity before fulfilling your request.

7. International Data Transfers

Your information, including Personal Data, is processed at our operating offices and on our hosting provider's servers, which are located in the United States. This means your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. We will take all steps reasonably necessary to ensure that your data is treated securely.

8. Security of Your Information

We use a variety of security measures to protect your personal information, including using SSL encryption for data in transit and hashing passwords. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

9. Children's Privacy

Our Service is not intended for use by anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If you become aware that a child has provided us with Personal Information, please contact us.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: privacy@surfluent.com