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Privacy Policy

Last updated: May 7, 2026


1. Data Controller

The data controller responsible for the processing of personal data on SurgeNiche under Art. 4 (7) GDPR is:

ELM Social Media

Inhaber: Viktor Martinovic

Hingbergstr. 322

45472 Mülheim an der Ruhr

Germany

Contact: support@surgeniche.com

2. What Data We Collect

We collect only the minimum data necessary to operate the Service:

3. Legal Bases for Processing (Art. 6 GDPR)

4. Sub-Processors

SurgeNiche relies on the following sub-processors. Each operates under its own GDPR-compliant data processing agreement and is selected for EU or adequacy-listed jurisdictions where possible:

We do not sell your personal data to any third party, nor share it for cross-context advertising.

5. International Transfers

Some sub-processors (e.g. Stripe, Anthropic, OpenAI, Sentry) operate infrastructure in the United States. Where personal data is transferred outside the EEA, we rely on the EU Standard Contractual Clauses (SCCs) as approved by the European Commission and, where applicable, the EU-US Data Privacy Framework, to ensure an adequate level of protection.

6. Your Rights Under GDPR

If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom, you have the following rights:

To exercise any of these rights, email support@surgeniche.com. We will respond within 30 days. You also have the right to lodge a complaint with the data protection authority of your jurisdiction; for users in Germany this is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW).

7. Cookies

We use two categories of cookies:

8. Data Retention

We retain account data (email, subscription status, saved niches) for as long as your account is active. Upon receiving a verified deletion request, we will delete your personal data within 30 days, subject to any legal retention obligations (e.g. tax records held by Stripe). Anonymized analytics data that cannot be linked back to you may be retained indefinitely for aggregate product research.

9. Children

SurgeNiche is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has signed up, contact us and we will delete the account.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in the Service or in applicable law. Material changes are reflected in the "Last updated" date at the top of this page; we may also notify you by email when changes affect how we process your data.

11. Contact

For any privacy-related questions, data requests, or complaints, email us at support@surgeniche.com. If you believe we have not adequately addressed your concern, you can lodge a complaint with your local data protection authority.