SUGO understands that your privacy is important to you. We want you to know that any personal data which you provide to us will be handled and stored with this in mind. We respect and value the privacy of all our customer and website users and will only collect and use personal data in the ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- What Does This Privacy Notice Cover?
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are Your Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 11 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that if data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.
Further information about your rights can also be obtained from the Information Commissioner’s Office.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Personal Data Do We Collect?
When you register your details with Us to find out about SUGO offers or our services, you will have to enter the following personal data through our website:
- Email Address
- How Do We Use Your Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.
We ask for your consent to process your data at the point at which we collect it which acts as our lawful basis for processing.
The personal data which you provide through this website page will be used to send you information about SUGO .
- How Long Will We Keep Your Personal Data?
Any personal data which you provide through this website will be retained until you unsubscribe from our mailing list or contact us directly for your information to be deleted, after which the personal data shall be securely erased.
This retention period does not limit your right to request that we delete, remove, or return any of your personal data that we hold in accordance with the GDPR.
- Your Right of Erasure (“Right to be Forgotten”)
Under the GDPR, you are entitled to request that We delete, destroy, return, or otherwise dispose of any and all personal data which we hold which relates to you.
If you would like to make such a request, please contact us by using the details set out above.
Please note that it may not be possible for Us to delete all the personal data which we hold relating to you if that data is necessary to complete the performance of an obligation or we are required to hold it by law.
- How and Where Do We Store or Transfer Your Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states plus Norway, Iceland and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
Please contact us using the details above for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we ensure that all personal data is stored on databases which as password protected.
Personal data which is held on Our computers is fully encrypted and Our computers are password protected.
- Do We Share Your Personal Data?
We may sometimes contract with third parties to supply products or services to you on our behalf. These may include payment processing and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights or obligations, and the third party’s obligations under the law, as described above in Part 8.
You are entitled at any time to request that your personal data not be used for a specific purpose, which includes for the purpose of marketing our services to you. Any communication which markets our services to you shall include a method by which you can opt-out of receiving further communications for that purpose.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
When you complete your registration with Us, some of the personal data which you provide will be passed to third parties as part of our registration process.
We use MailChimp to communicate our new offers and events.
We are entitled to share your information with these partners as it is within our legitimate business interests to do so.
While we try to ensure that third parties process your information in accordance with your rights, the data which you provide to these third parties will be subject to their privacy policies which We would advise that you read and understand.
- How Can You Access Your Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown on our website.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Please review this policy from time to time to make sure you are aware of how we are using your data and your rights.
Last updated: September 25, 2019
What are cookies?
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
When you use and access the Service, we may place a number of cookies files in your web browser.
- To enable certain functions of the Service
- To provide analytics
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
- Essential cookies: We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
- Analytics cookies: We may use analytics cookies including Google Analytics & Facebook pixel to track information for example how the Service is used, so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.
What is Google Analytics?
Google Analytics is a simple, easy-to-use tool that helps website owners measure how users interact with website content, it is the most widely used web analytics service on the internet.
Google Analytics mainly uses first-party cookies to report on user interactions on Google Analytics customers’ websites.
This free service from Google that lets you see detailed statistics about how users interact with your website/app including traffic, average time on site, geographic location of visitors and other useful metrics.
It also incorporates marketing tools such as AdWords and remarketing advertising capabilities.
The Google Analytics security and privacy documentation: https://support.google.com/analytics/answer/6004245
What is Facebook Pixel?
The Facebook pixel is an analytics tool that allows you to measure the effectiveness of your advertising by understanding the actions people take on your website. You can use pixel data to:
- Make sure your ads are being shown to the right people
- Build advertising audiences
- Unlock additional Facebook advertising tools
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
- For the Opera web browser, please visit this page from Opera: http://www.opera.com/help/tutorials/security/cookies/
- For any other web browser, please visit your web browser’s official web pages.
Where you can find more information about cookies
You can learn more about cookies and the following third-party websites:
- AllAboutCookies: http://www.allaboutcookies.org/
- Network Advertising Initiative: http://www.networkadvertising.org/
- Google Analytics Cookie Usage on Websites: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
- About Facebook Pixel: https://www.facebook.com/business/help/