Privacy Policy

Last updated: August 17, 2026

1. Who We Are

SurplusEdges is operated by Spain Companies LLC ("SurplusEdges," "we," or "us"), located in Hermosa Beach, California. We are the data controller responsible for your personal information collected through this website.

2. Information We Collect

2.1 Information You Provide

When you join our waitlist, we collect:

• Email address — required to notify you of product availability.
• Company name — optional, for market segmentation.
• Seat count estimate — optional, for capacity planning.
• Tier of interest — optional, for demand assessment.
• UTM parameters — campaign/referrer data from the link you clicked, for marketing attribution.

2.2 Automatically Collected Information

Our scenario pages automatically run the compliance calculator with a default surplus amount ($48,500) when loaded. This generates an anonymous event containing the selected state, surplus amount, computed fee cap, and UTM/referrer values. This event is not linked to your identity unless you have separately provided your email on the same visit.

We do not currently deploy third-party analytics (such as Google Analytics or similar). We plan to add privacy-configured analytics before the product launches, at which point this policy will be updated.

2.3 Cookies

We do not set advertising cookies. Our website uses a single first-party preference (theme selection: light or dark mode) stored in the browser. We do not use tracking pixels, ad networks, or third-party cookie providers at this time.

3. How We Use Your Information

• To notify you when the SurplusEdges product becomes available in your state.
• To assess market demand and plan product features and pricing.
• To measure which marketing campaigns drive waitlist signups.
• To respond to your inquiries and provide support.

We do not sell your personal information to third parties.

4. Legal Basis (GDPR)

For users in the European Economic Area, our legal basis for processing your email address and waitlist information is consent (Article 6(1)(a) of the GDPR). You may withdraw consent at any time by emailing us at bspain@spaincos.com. For anonymous calculator analytics, the legal basis is legitimate interest (Article 6(1)(f)) in understanding product demand, as these events are not linked to your identity.

5. Data Retention

• Waitlist data: Retained until you request deletion or until 24 months after the product launches, whichever comes first.
• Anonymous calculator events: Retained for up to 12 months for aggregate analytics, then automatically purged.
• UTM/referrer data: Retained alongside the associated waitlist or analytics record.

6. Subprocessors

We use the following third-party service providers to operate the website:

• Supabase (Supabase Inc.) — database hosting and API backend for waitlist and calculator event storage. Data is stored in the United States.
• Vercel (Vercel Inc.) — website hosting and content delivery. Server logs may include IP addresses.
• Fontshare and Google Fonts — web font delivery. These providers may receive your IP address when your browser loads fonts.

We do not use any advertising networks, data brokers, or analytics providers at this time.

7. Data Security

We protect your data using row-level security policies on our database, publishable (non-secret) API keys for public form submission, and HTTPS encryption for all data in transit. Waitlist and calculator data are stored in separate database tables with access controls. Only authorized personnel with service-role database access can read waitlist submissions.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Request access to your personal data.
• Request correction or deletion of your personal data.
• Object to or restrict certain processing.
• Withdraw consent (where processing is based on consent).
• Request data portability.
• File a complaint with a supervisory authority.

To exercise any of these rights, email bspain@spaincos.com.

9. Cross-Border Transfers

Your data is stored on servers located in the United States (Supabase and Vercel). If you are accessing this website from outside the United States, your information will be transferred to the United States. By using this website, you consent to this transfer.

10. Children's Privacy

This website is not directed to children under 16, and we do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy at any time. We will post the updated version on this page and revise the "Last updated" date. We will notify you of material changes by email if you are on our waitlist.

12. Contact

Spain Companies LLC
Hermosa Beach, California
Email: bspain@spaincos.com

This Privacy Policy is a draft prepared for legal review and is not effective until finalized by counsel.