1. Introduction

Supercode (“we”, “us”, “our”) is committed to protecting your privacy and treating your data with respect. This Privacy Policy explains how we collect, use, and protect your personal information when you use our mobile app, website, and related services (collectively, the “Services”).

Supercode is owned and operated by Ministry of Trust, Inc., headquartered in Houston, Texas.

2. What This Policy Covers

This policy applies to all users of our Services, including mobile and web applications, customer support, and marketing channels.

It explains:

What personal data we collect

How and why we use it

How we share and protect it

How you can control it

Your rights under laws such as the GDPR, CCPA, COPPA and other applicable regulations

3. Who We Are

Supercode is a human-to-human identity verification and 2FA (two-factor authentication) platform that helps individuals and teams verify each other’s identity using shared, secure codes.

Our mission is to redefine digital trust by giving users a simple, secure, and human way to confirm authenticity in an age of AI impersonation and scams.

4. Information We Collect

a) Information You Provide

When you use our Services, we may collect:

Your name, email address, and/or phone number

Account details and credentials (such as recovery contacts or trusted users)

Content you upload or protect with Supercode (e.g., links, files, and notes)

Payment details when you purchase Supercode Max or other paid features

Support inquiries and feedback messages

b) Information We Collect Automatically

When you interact with our Services, we may collect:

Device and app information (model, operating system, version, language, etc.)

IP address, browser type, and time zone

Usage analytics, such as actions taken in-app or error/crash reports

Cookies and similar technologies for performance, analytics, and security

c) Information from Third Parties

We may receive information from:

Analytics providers (e.g., Google Analytics, RevenueCat)

App store platforms (Apple, Google)

Marketing or advertising partners

Business partners if you use Supercode within an organization

5. How We Use Your Information

We use your personal information to:

Provide, maintain, and improve our Services

Authenticate you and enable secure code-based verification

Process payments and manage subscriptions

Communicate with you about your account or updates

Detect and prevent fraud, abuse, or unauthorized access

Improve app performance and user experience through analytics

Comply with legal and regulatory obligations

We never sell your data. Period.

6. Legal Bases for Processing (for GDPR and other laws)

Where applicable, we process your personal data under one or more of the following legal bases:

Contractual necessity: to provide you the Services you requested

Legitimate interests: to secure, optimize, and improve our Services

Consent: for optional analytics, marketing, or newsletters

Legal obligation: to comply with applicable law or regulatory requirements

7. How We Share Information

We may share your information with:

Service providers (e.g., cloud hosting, analytics, customer support)

Payment processors (e.g., Apple, Google, RevenueCat)

Legal authorities if required by law or court order

Business partners if you connect with them via Supercode

Affiliates or successors in case of mergers or acquisitions

All third-party processors are bound by confidentiality and data protection agreements.

8. Data Retention

We retain your personal data only for as long as necessary:

To provide the Services

To comply with legal obligations

To resolve disputes and enforce agreements

When no longer needed, your data is securely deleted or anonymized.

You can request account deletion at any time by contacting legal@supercode.co

.

9. GDPR & International Privacy Rights

If you are located in the European Economic Area (EEA), United Kingdom (UK), or other regions with similar laws, you have the following rights:

Your Rights

Access – Request a copy of your personal data.

Correction – Ask us to fix inaccurate or incomplete data.

Erasure (“Right to be Forgotten”) – Ask us to delete your personal data.

Restriction – Limit how we process your data.

Portability – Receive your data in a portable format.

Objection – Object to processing based on legitimate interests.

Withdraw Consent – Withdraw consent at any time for optional processing.

You can exercise these rights by emailing us at legal@supercode.co

10. Children’s Privacy & COPPA Compliance

Supercode is designed with families and child safety in mind. We comply with the U.S. Children’s Online Privacy Protection Act (COPPA) and never knowingly collect, use, or share personal information from children under 13 without verified parental consent.

Our Family Key system ensures that a parent or legal guardian controls the child’s account and all related permissions. Children under 13 can only use Supercode after a parent has created a Family Key and linked the child’s account. This prevents unauthorized users from connecting with or sending codes to a child.

Parents and guardians can:

Review the personal information collected from their child,

Request deletion of their child’s data, or

Withdraw consent at any time.

To exercise these rights or ask questions about your child’s data, please contact us at legal@supercode.co

.

If we ever learn that a child’s account was created without parental consent, we will immediately delete that account and its associated information.

11. Children’s Privacy

Supercode is not intended for children under 16 years old unless used with parental consent (for example, in “family protection” mode).

If we learn that we have collected information from a child without consent, we will delete it immediately.

12. Security

We employ industry-standard security measures, including:

Secure storage and key management

Regular security audits and penetration testing

Limited employee access to production data

While no system is 100% secure, we are committed to maintaining the highest levels of protection for your information.

13. Cookies and Tracking

We use cookies and similar technologies to:

Remember your preferences

Improve app performance

Measure analytics and conversions

You can manage cookies through your browser settings or device preferences.

Cookies and Tracking Technologies

For full details, see our Cookie Policy or contact us at legal@supercode.co

14. Updates to This Policy

We may revise this Privacy Policy periodically.

If changes are significant, we’ll notify you via email or in-app notification.

The “Effective Date” at the top will indicate the latest update.

15. Contact Us

If you have questions, concerns, or would like to exercise your rights, contact us at:

Supercode Privacy Office

Ministry of Trust, Inc.

1501 S Mopac Expy, Ste 220, Austin, TX 78746

Email: legal@supercode.co

We will respond promptly in accordance with applicable privacy laws.