If you have questions regarding this policy or our handling of your personal information, please email us at email@example.com.
Our legal status under UK data protection law is that of a data controller, and in this capacity we will securely store and process your personal information which you have provided to us. Data controller is a legal term used in the Data Protection Act 1998 (the Act) to signify the person who controls what to do with any given personal information. As data controller we have registered with the Information Commissioner’s Office and our registration number is ZA218199.
collection of information
- your first and last names;
- your date of birth;
- your email address;
- your mobile phone number;
- details of your contacts;
- metadata relating to any messages you send using the Huggg Service; and
- the content of any messages you send using the Huggg Service.
This information (and any payment information) may be collected by us or on our behalf by our third-party partners from time to time. You are not required to provide any of this information but, if you do not, we may not be able to provide you with the requested services.
How is your personal information used?
We will use the personal information you provide to us to:
- notify you that our app is enabled for you to download;
- enable you to download our app;
- provide you with our services which you have signed up for;
- provide occasional updates, including marketing messages from us;
- provide personalized communications from us;
- enable you to receive Hugggs;
- identify you in online/offline communications;
- restrict the purchase of age-restricted items to persons over the required age;
- deliver targeted advertisements to you and others as you browse the internet;
- better understand how you interact with and use the Huggg Service; and
- develop our offering and the layout of the Huggg Service to ensure that our services are as useful and enjoyable as possible.
with whom is your personal information shared?
We will never sell, trade, or rent your personal information to others, however we may share your information with selected third parties including:
- advertisers and advertising networks that require the data to select and serve adverts about our services to you and others. It will only be passed to third party advertisers 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 identifying 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.
how long do we retain your personal information?
We will retain your personal information for so long as you are registered with the Huggg Service and for up to 6 years thereafter. Where such personal information is no longer necessary we may delete it sooner.
The requirements of data protection law
- 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 not transfer your personal information outside the European Economic Area 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 information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure. For example, we procure the storage of personal information you provide on cloud storage facilities, access to which is limited using password protection.
You have the following rights in relation to your personal data:
- a right of access to a copy of the information comprised in your personal data;
- a right to object to processing that is likely to cause or is causing damage or distress;
- a right to object to decisions being taken by automated means;
- a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
- a right to claim compensation for damages caused by a breach of the Data Protection Act.
If you are unsure about your rights or are concerned about how your personal data may be processed you should contact the Information Commissioner’s Office.
If you contact us in relation to your rights we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute.
Please send us an email at firstname.lastname@example.org if you would have any queries about, or would like to enforce, your rights set out above.
reviewing your personal information
In some cases, you can review and correct personal information provided through the Huggg Service by going to the page on which you provided the information. In all cases, you can make a subject access request to review your personal information collected via the Huggg Service or ask us to stop using it by sending us an email at email@example.com. We may take steps to verify your identity before providing you access to your personal information and may request a small administrative fee. You can help us to maintain the accuracy of your information by notifying us of any change.
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.
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.
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 withdraw your consent to us using Google Analytics at any time. If you wish to do so, please send us an email at firstname.lastname@example.org.
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 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.
By using the Huggg Service you consent to us using the above cookies.