Privacy Policy

We will only use your personal data when permitted to do so in accordance with data protection laws, which means that we will only process your personal data where we have a lawful basis for doing so.

Your personal data may be collected by us or on our behalf by our third-party partners such as payment services providers, identity providers and other software services, including telecommunications services.

In respect of your personal data that we process, these bases are as follows: (i) where you have given your consent for us to use your personal data for a particular purpose (Consent); (ii) where the processing of your personal data is necessary for the performance of our contract with you (Contract); (iii) where the processing of your personal data is required to comply with a legal or regulatory obligation (Legal Obligation); or (iv) where the processing of your personal data is in our (or a third party’s) legitimate interests and your freedoms and fundamental rights do not override those interests (Legitimate Interests).

If you use the Huggg Service to buy somebody a Huggg, we may send them a text message to let them know. We receive their mobile phone number from you and you confirm that you have their permission to share this with us for this purpose.

Specifically, the following are the purposes for which we process your personal data and the lawful bases on which we rely to carry out such processing:

Where we have indicated in this Privacy Policy that we process your personal data because it is necessary to perform a contract that we have with you, if you provide us with incorrect information or if you do not provide the information we request at all we may not be able to perform our obligations to you under that contract, or this could lead to a delay in us performing those obligations, for example if you provide us with incorrect mobile phone details for your recipient we may not be able to deliver the Huggg which you purchase.

We will never sell, trade, or rent your personal information to others, however we may share your information with selected third parties including:

• advertisers, agencies and advertising networks that require the data to select and serve adverts or provide outbound and outbound sales services regarding our services to you and others. It will only be passed to such parties in order to provide services on our own behalf; and
• third party data, service and software providers that assist us in the function, improvement and optimisation of our applications.

We may also disclose depersonalised data (such as aggregated statistics) about the users of the Huggg Service in order to describe our sales, customers, traffic patterns and other information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

We may occasionally be required by law, court order or governmental authority to disclose certain types of personal information. Examples of the type of situation where this would occur are:

• in the administration of justice; and
• where we have to defend ourselves legally.

Finally, in the event of a reorganisation, sale or takeover we may need to disclose personal information to new entities within our group or potential acquirers and our and their advisers.

We will retain your personal data for so long as you are registered with the Huggg Service and for up to 6 years thereafter unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements. Where such personal data is no longer necessary we may delete it sooner.

We regard the lawful and correct treatment of your personal information by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal information lawfully and correctly. To this end we fully endorse and adhere to our obligations under data protection laws. In particular:

• we will not use your personal information for any purpose that is incompatible with this Privacy Policy;
• we will only collect sufficient personal information for the uses set out above;
• we will endeavour to keep your personal information up-to-date;
• we will not retain your personal information longer than necessary unless required to do so by law;
• we will operate appropriate technical and organisational processes to protect your personal information against unauthorised or unlawful access or processing and against accidental loss or destruction; and
• we will not transfer your personal information outside the European Economic Area to a country which does not offer the same level of protection as that offered by data protection laws which apply to us, such as the GDPR, unless safeguards are in place to protect your personal information to the standards that apply within the EEA.

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access, use, or disclosure.

For example, we procure the storage of personal data you provide on cloud storage facilities, access to which is limited using password protection and 2-Factor Authentication.

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
• Request erasure of your personal data (commonly known as a “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no lawful basis for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on legitimate interests (or those of a third party) and  you want to object to processing.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.
• In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to. Please note, however, that in most cases we do not rely on your consent to process your personal data.
• Complain to a relevant supervisory authority in respect of our processing of your personal data, such as the Information Commissioner’s Office in the UK. However, if you have any concerns about how we handle your personal data, we encourage you to contact us in the first instance so that we can work with you to resolve them.

If you want to exercise your rights over your personal data please send us an email at hello@huggg.me.

You can also opt-out of marketing at any time by contacting us at hello@huggg.me or following the instructions to unsubscribe within the marketing message.

You will not have to pay a fee to exercise any of your rights. However, we may refuse to comply with your request if it is clearly unfounded or excessive.

Please be aware that the rights above are not absolute and there may be circumstances where we are unable to (or are not obliged to) comply with your request (either wholly or in part). In such cases we will explain why we cannot comply with the request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is to ensure that personal data is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to. Please note, however, that in most cases we do not rely on your consent to process your personal data.

We are required to ensure that the personal data we hold about you is accurate and up-to-date. Therefore we request that you notify us as soon as possible of any changes to your personal data.

We do not knowingly collect information from children and do not target or direct our site to children. Where we do collect information from children we will ensure that all processing and information provided is appropriate to the age of the child.

Cookies are small files that websites save to your hard disk or to your browser’s memory. You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not be able to fully experience the features of the Huggg Service or other websites that you visit and apps that you use. To learn more about cookies and how to disable them we recommend you visit the Information Commissioner’s website here.

The types of cookies used on the Huggg Service are set out below. Promotional cookies collect information about your browsing in order to deliver promotions relevant to you and your interests as well as your IP address in order to determine your geographic location and for fraud filtering. They are usually placed by third party advertising networks. They remember that you have visited a website and this information is shared with other organisations such as media publishers.

These organisations do this in order to provide you with targeted adverts more relevant to you and your interests. This type of advertising can include targeting you based on what pages of our applications you have visited and online behavioural advertising based on your browsing history. You can learn more about third party marketing cookies and how to delete them here.

We may from time to time use this type of cookie on our applications to deliver promotions relevant to you. Promotional cookies may also be used to limit the number of times you see a promotion as well as help measure the effectiveness of the promotion.

When we send you an email, we may track whether you have opened that email and whether you have clicked any links it may contain. This helps us measure and improve the performance of our email campaigns.

Our applications use Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). The cookies used by Google Analytics are third party cookies referred to above, and help our applications analyse how you use them. The information generated by the cookie about your use of our applications (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to provide us with reports on application activity and other services relating to application activity. For more information about how Google uses your data please see Google’s Privacy & Terms. You can opt out of Google Analytics cookies by using this Google Analytics Opt-Out Add-on.

Social Sharing Cookies provide you with additional functionality to share content from our applications to social media websites and email using the social media widgets or buttons found on our applications. Use of these widgets or buttons may place a cookie on your device to make their service easier to use and to ensure your interaction is displayed on webpages (e.g. the social share count cache is updated). We encourage you to review each provider’s privacy information before using any such service.

The cookies we use, including analytics cookies, are used solely in relation to the provision of the Huggg Service, advertising and so as to better understand how you interact with the Huggg Service. They allow us to:

• monitor the number of people using our websites and applications and monitor their activities;
• see how people arrive at our website and applications;
• gather technical information about people using our websites and applications, such as their geographic location and the type of web browsers they are using; and
• display adverts on other websites and applications, to people who have previously accessed our websites and applications. We cannot identify individuals to whom adverts may be displayed.