Privacy Policy
Sulvo Europe OÜ, its subsidiaries and affiliate companies (collectively, "Sulvo", hereinafter referred to as "Sulvo") constantly develop and implement security enhancements to ensure the confidentiality of your personal, non-public information while accessing your online account.
At Sulvo, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected, recorded, stored and deleted by sulvo.com and how we use it. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at privacy@sulvo.com.
This Privacy Policy has been compiled to better serve those who are concerned with how their "Personally identifiable information" (PII), "Personal Data" and "User Personal Information" are being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. "Personal Data" means any information relating to an identified or identifiable person, including laws and regulations of the European Union. "User Personal Information" is any information about a user which could, alone or together with other information, personally identify him or her. Information such as a username and password, an email address, a real name, and a photograph are examples of "User Personal Information". "User Personal Information" does not include aggregated, non-personally identifying information to operate, improve and optimize our website and service. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information, Personal Data and User Personal Information in accordance with our website.
Sulvo in ChatGPT
When you use the Sulvo plugin in ChatGPT or Codex, our server receives the website domain you ask about, any site category and traffic or revenue figures you choose to share, and the diagnostic settings for your request. It checks only public website information, such as the homepage, sampled content pages, ads.txt, robots.txt, public advertising configuration files, and HTTPS certificates. We use these inputs to produce the diagnostic you request.
We return the diagnostic results to OpenAI so they can be shown in ChatGPT or Codex. Railway, our hosting provider, processes requests on our behalf. If you request a PageSpeed check, we send the public page URL to Google's PageSpeed Insights service. We do not send your traffic or revenue figures to that service.
The diagnostic tools process your inputs and results in temporary memory while answering your request. They do not save those inputs or completed diagnostic results to a database or disk. Technical access and error logs are covered by the Data Retention section below and may include request metadata or error details.
We do not sell these inputs or results. The plugin does not ask for your name, email, or password, and it does not require or access a Sulvo account. You choose whether to provide optional traffic or revenue figures. For privacy questions or to exercise the data rights described in this policy, contact privacy@sulvo.com.
Copies of your requests and results in ChatGPT or Codex are handled by OpenAI under its applicable privacy policy and service terms. You can manage your ChatGPT conversations through OpenAI's data controls. OpenAI Privacy Policy.
What personal information do we collect from the people that visit our blog, website or app?
If you are just visiting the website, we collect the same basic information that most websites collect. We use common internet technologies, such as cookies and web server logs. We collect this information from everybody who entered our website, whether they have an account or not. The information we collect about all visitors to our website includes the visitor’s browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. We also collect potentially personally identifying information like Internet Protocol (IP) addresses.
What personal information do we collect from users when using or registering on our site?
When using or registering on our site, as appropriate, you may be asked to enter your cookies or other details to help you with your experience. When becoming a Sulvo partner, you will be required to provide email and other personal data to set up an account.
When you create an account, we require some basic information at the time of the account creation. You will create your own username and password, and we ask you for a valid email account. You also may be required to provide more information, and this may include "User Personal Information".
Why do we collect this information?
We collect this information to better understand how our website visitors use Sulvo, and to monitor and protect the security of the website.
When do we collect information?
We collect information from you when you visit or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To create and administer your account.
- To improve our website or application in order to better serve you.
- To allow us to better service you in responding to your customer service inquiries and requests.
- Conduct Research and analysis.
- Analyze Data, including through automated systems and machine learning to improve our services and your experience.
- Provide you information about your use of the services and benchmarks, insights and suggestions for improvements.
How do we protect visitor information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We only provide articles and information, and we never ask for personal or private information as a visitor.
How do we protect user information?
Our application is scanned on a regular basis for security holes and known vulnerabilities in order to make our application as safe as possible. We use an SSL certificate whenever you enter personal information on our site or application.
Do we use 'cookies'?
Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We use cookies to:
Keep user sessions open.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies. You may also manage your cookie preferences through our cookie consent banner.
If you disable cookies some features will be disabled and may not function properly. It may affect the user experience that makes your site experience more efficient and some of our services will not function properly. However, you can continue to access our website and application.
Third Party Disclosure
Ensuring your privacy is important to us. We do not share your personal information with third parties except as described in this Privacy Policy. We may share your personal information with (a) third party service providers, (b) business partners (c) affiliated companies with our corporate structure, (d) as needed for legal purposes. Third party service providers have access to personal information only as needed to perform their functions and they must process the User Personal Data in accordance with this Privacy Policy.
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. Examples of how we may disclose data for legal reasons include (a) as part of a merger, sale of company assets, financing or acquisition of all or a portion of our business by another company where customer information will be one of the transferred assets, (b) as required by law, for example, to comply with a valid subpoena or other legal process; when we believe in good faith that disclosure is necessary to protect our rights, or to protect your safety; to investigate fraud or to respond to government request.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are shown to provide a positive experience for users.
We have not enabled Google AdSense on our site but we may do so in the future.
For Google’s privacy policy, please visit https://policies.google.com/privacy.
General Data Protection Regulation ("GDPR")
Sulvo Europe OÜ is established in the European Union and is directly subject to the General Data Protection Regulation (GDPR). We process personal data of EU/EEA residents in compliance with GDPR requirements.
We process your personal data under the following legal bases: (a) performance of a contract when providing our Services to you; (b) our legitimate interests in operating and improving our Services, provided these interests do not override your fundamental rights; (c) your consent, where specifically requested; and (d) compliance with legal obligations.
Under GDPR, you have the following rights regarding your personal data: (a) Right of access: to request a copy of your personal data; (b) Right to rectification: to request correction of inaccurate data; (c) Right to erasure: to request deletion of your personal data, subject to legal retention requirements; (d) Right to restriction of processing: to request that we limit our processing of your data under certain circumstances; (e) Right to data portability: to receive your personal data in a structured, commonly used, and machine-readable format; (f) Right to object: to object to processing based on legitimate interests, including direct marketing; (g) Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
To exercise any of these rights, contact our Data Protection Officer at privacy@sulvo.com. We will respond to your request within thirty (30) days. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or another supervisory authority in the EU Member State of your habitual residence.
California Online Privacy Protection Act of 2003 (CalOPPA)
CalOPPA is the first state law in the US to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California residents to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.
California Online Privacy Protection Act (CalOPPA)
According to CalOPPA we agree that: Users can visit our site anonymously. Once this privacy policy is approved, we will disclose it by adding a link to it on our home page, or as a minimum on the first significant page after entering our website. Our Privacy Policy link includes the word 'Privacy', and can be easily found on the page specified above. Users will be notified of any privacy policy changes: Subject to certain limits under California Law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request California residents may contact us as specified in the Contact Us section or by sending an email to privacy@sulvo.com.
Does our site allow third party behavioral tracking?
It's also important to note that we allow third party behavioral tracking.
Children Online Privacy Protection Act ("COPPA") of 1998
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) of 1998, as amended puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. Sulvo does not specifically market its products and services to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without parental consent, we will promptly delete that information. Additionally, for California residents under 16 years of age, we will not sell or share personal information without affirmative authorization as required by the CCPA/CPRA.
Fair Information Practices
The Fair Information Practices (FIP) are a set of standards governing the collection and use of personal data and addressing issues of privacy and accuracy. There should be limits to the collection of personal data and any such data should be obtained by lawful and fair means and, where appropriate, with the knowledge or consent of the data subject.
As an individual user, under the FIP, you have the right to (a) obtain from a the Sulvo’s Privacy Officer, confirmation of whether or not the data controller has data relating to you; (b) to have communicated to you data relating to you within a reasonable time; at a charge, if any, that is not excessive; in a reasonable manner; and in a form that is readily intelligible to you; (c) to be given reasons if a request made under (a) and (b) is denied, and to be able to challenge such denial; and to challenge data relating to you and, (d) if the challenge is successful to have the data erased, rectified, completed or amended.
In order to be in line with Fair Information Practices and GDPR we will take the following responsive action, should a high risk data breach occur:
Where a data breach in Sulvo may pose a high risk to the rights and freedoms of our users, Sulvo will: (a) notify the competent supervisory authority (the Estonian Data Protection Inspectorate, or the relevant authority in the EU Member State where the breach occurred) within seventy-two (72) hours of becoming aware of the breach, as required by GDPR Article 33; and (b) notify affected users without undue delay via email, with relevant details in clear language about the nature of the breach, the likely consequences, and the measures taken or proposed to address it, as required by GDPR Article 34.
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
California Civil Code Section 1798.83 permits Users of the Program that are California residents to request certain information regarding our disclosure of the information you provide through the Program to third parties for their direct marketing purposes. To make such a request, please contact us at the following address: privacy@sulvo.com.
Cookie Categories:
Analytics Cookies: Help us understand how visitors interact with our website by collecting and reporting information anonymously. These cookies allow us to count visits and traffic sources to measure and improve site performance.
California Consumer Privacy Act / California Privacy Rights Act ("CCPA/CPRA")
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). Sulvo does not sell your personal information as defined under the CCPA, and does not share your personal information for cross-context behavioral advertising purposes.
As a California resident, you have the right to: (a) Right to Know: request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purpose for collecting the information, and the categories of third parties with whom we share the information; (b) Right to Delete: request the deletion of personal information we have collected from you, subject to certain exceptions; (c) Right to Correct: request the correction of inaccurate personal information; (d) Right to Opt-Out: direct us not to sell or share your personal information; (e) Right to Non-Discrimination: not be discriminated against for exercising any of your CCPA/CPRA rights.
To exercise these rights, contact us at privacy@sulvo.com. We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf. If you are under 16 years of age, we will not sell or share your personal information without affirmative authorization.
Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, and in accordance with applicable law. Specifically: (a) Account data (e.g., username, email, account settings) is retained for the duration of your account and deleted within thirty (30) days of account closure or termination; (b) Server logs and access records are retained for ninety (90) days; (c) Cookie data is retained according to the cookie type and your consent settings (see Cookie Categories above); (d) Notwithstanding the above, we may retain certain data for longer periods where required by law (e.g., tax, audit, or legal hold obligations) or to resolve disputes, enforce agreements, or protect our legal rights.
International Data Transfers
Sulvo Europe OÜ is established in the European Union (Estonia). Your personal data is primarily processed within the EU/EEA. Where data is transferred outside the EU/EEA (for example, to service providers in the United States), we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, decisions of adequacy, or other lawful transfer mechanisms under GDPR Chapter V. You may request a copy of the safeguards in place by contacting us at privacy@sulvo.com.
Automated Decision-Making
Sulvo uses automated systems, including bot scoring and filtering technology, to assess the quality of ad impressions and detect invalid traffic. These automated processes do not produce legal effects or similarly significant effects on individuals. No solely automated decisions are made that affect your legal rights or contractual relationship with Sulvo. If you have concerns about our use of automated processing, please contact us at privacy@sulvo.com.
Governing Law
This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of laws principles. For EU/EEA residents, this does not affect your rights under GDPR or applicable local data protection laws, including your right to lodge a complaint with your local supervisory authority.
Applicability of this Privacy Policy
This Privacy Policy is strictly limited to Sulvo Services and has no effect on any other privacy policy(ies) that may govern the relationship between you and us in other contexts.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will provide notice on this website, and we may notify you by email (sent to the email address specified in your account), prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. If you continue to use Sulvo Services after those changes are in effect, you agree to the revised policy.
Contacting Us
If there are any questions regarding this Privacy Policy you may contact us using the information below.
Email: privacy@sulvo.com
Effective Date: April 6th, 2026
Last Updated: October 3rd, 2026