Draft — pending operator review. Not yet approved as an official legal statement.
SAM
Draft policy · 21 October 2026

Privacy Policy

1. Operator and scope

SAM is a private executive operations platform operated by Surooh Holding Group B.V. This document describes the Google access scopes currently configured for the SAM OAuth application. The operational deployment and its data handling are undergoing final review.

2. Data accessed

With account-owner authorization, SAM may access Gmail messages and metadata via gmail.readonly and Google Drive file/folder metadata via drive.metadata.readonly. The latter permission does not grant access to document contents. Other optional capabilities may exist in SAM software, but are not granted through these two OAuth scopes.

3. Purposes

Authorized business correspondence review, file discovery, operational coordination, and internal reporting.

4. Google API data and limited use

SAM's use and transfer of information received from Google APIs is intended to adhere to the Google API Services User Data Policy, including Limited Use requirements. Google user data is not sold or used for advertising.

5. Service providers and storage

SAM runs using cloud infrastructure and business-service integrations. Operational information and technical logs may be processed or stored by the application and its providers. A confirmed list of processors, storage locations, and detailed data flows is still under review; no specific retention or deletion guarantee is made here.

6. Security

The platform is designed for authorized owner access and uses OAuth to authorize Google access. Detailed operational security controls, access logs, and incident procedures remain subject to verification.

7. Retention and deletion

Actual retention periods, logs, backups, and deletion procedures require verification. Requests about access or deletion can be sent to the operator at the contact email below.

8. Requests and contact

Contact ceo@suroohholdings.com for privacy requests. Applicable privacy rights depend on the relevant laws and circumstances.

9. Updates

The operator may update this draft to reflect verified implementation and applicable requirements.